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    HMRC Fights Back:Two Restructuring Plans Refused Sanction by the English Court
    2023-05-30

    In a dramatic reversal of restructuring plan fortunes, HRMC recently successfully challenged two independent mid-market Part 26A Companies Act 2006 restructuring plans: the Nasmyth Group Limited Restructuring Plan (the Nasmyth RP) and the Great Annual Savings Company Ltd Restructuring Plan (the GAS RP). To date, only one other restructuring plan has been refused sanction.

    Filed under:
    United Kingdom, Insolvency & Restructuring, Tax, Ashurst, HM Revenue and Customs (UK), Companies Act 2006 (UK)
    Authors:
    Olga Galazoula , Richard Bulmore , Ru-Woei Foong , Drew Sainsbury , Inga West
    Location:
    United Kingdom
    Firm:
    Ashurst
    The AVANTI spectrum Refinement to the legal characterisation of a charge as fixed or floating
    2023-05-26

    The characterisation of a charge as fixed or floating can have significant ramifications for the chargee on chargor’s insolvency. This is because the holder of a fixed charge enjoys significant advantage, in terms of the order of priority of distributions to creditors, over a floating charge holder.

    Filed under:
    United Kingdom, Insolvency & Restructuring, Litigation, Tax, DLA Piper, Financial Conduct Authority (UK), HM Revenue and Customs (UK)
    Authors:
    David Ampaw , Roya Panahi
    Location:
    United Kingdom
    Firm:
    DLA Piper
    GAS - HMRC successfully opposes another restructuring plan by challenging the expert evidence and overall fairness
    2023-05-24

    On 16 May 2023, Mr Justice Adam Johnson in the High Court refused to sanction the restructuring plan proposed by The Great Annual Savings Company Limited (GAS) following objections from HMRC.

    Filed under:
    United Kingdom, Insolvency & Restructuring, Litigation, Tax, Freshfields Bruckhaus Deringer, HM Revenue and Customs (UK)
    Authors:
    Craig Montgomery , Frank Clarke , Katharina Crinson , Alice Gossop
    Location:
    United Kingdom
    Firm:
    Freshfields Bruckhaus Deringer
    Does tax have special status in Restructuring Plans? An examination of GAS and Nasmyth
    2023-05-22

    The English Court has refused to sanction two separate restructuring plans proposed by Nasmyth Group Limited (Nasmyth) and The Great Annual Savings Company Ltd (GAS). Both companies sought to use Part 26A of the Companies Act 2006 to “cram down” His Majesty’s Revenue and Customs (HMRC). Whilst neither decision is the first time that Part 26A has been used in this way1, they are the first to involve any active participation by HMRC in the sanction hearing2.

    Filed under:
    United Kingdom, Insolvency & Restructuring, Litigation, Tax, DLA Piper, HM Revenue and Customs (UK)
    Authors:
    David Ampaw
    Location:
    United Kingdom
    Firm:
    DLA Piper
    Avanti Communications Ltd - High Court considers fixed charges in context of administration sale
    2023-05-23

    In the recent case of Avanti Communications Limited (in administration) [2023] EWHC 940 (Ch), the High Court revisited the perpetually knotty question: what level of control is necessary for a charge over assets to take effect as a fixed, rather than floating, charge?

    Filed under:
    United Kingdom, Insolvency & Restructuring, Litigation, Tax, Stevens & Bolton LLP, Employee Retirement Income Security Act 1974 (USA), HM Revenue and Customs (UK), House of Lords
    Authors:
    Tim Carter , Helen Martin
    Location:
    United Kingdom
    Firm:
    Stevens & Bolton LLP
    English Court Refuses to Cram Down the Taxman
    2023-05-23

    Since their introduction to the English insolvency regime in 2020, court sanctioned restructuring plans under Part 26A of the UK Companies Act 2006 – a new, more-flexible alternative to traditional UK restructuring tools – which take some of their DNA from U.S. Chapter 11 bankruptcy proceedings (in particular, the ‘cross class cram down’ mechanism), have been a hot topic for insolvency lawyers.

    Filed under:
    United Kingdom, Insolvency & Restructuring, Vedder Price PC, Insolvency, HM Revenue and Customs (UK), Companies Act 2006 (UK), Corporate Insolvency and Governance Act 2020
    Authors:
    Trevor Wood , Nicholas J. Pascal , Henrietta Worthington , Samuel Wilson
    Location:
    United Kingdom
    Firm:
    Vedder Price PC
    (UK) What are the Key Takeaways for future Restructuring Plans following the GAS sanction hearing?
    2023-05-18

    What can we say about the outcome of the GAS (Great Annual Savings Company Limited) sanction hearing that hasn’t already been reported?

    It’s impossible not to comment on the fact that the plan was not sanctioned, and as a consequence of fierce opposition from HMRC that it avoided cram down. Nor that the court refused to sanction the plan on the basis that the conditions for cram down were not met – the court was not satisfied that HMRC would be better off under the plan and even if it were the judge said he would have not exercised his discretion to cram down.

    Filed under:
    United Kingdom, Company & Commercial, Insolvency & Restructuring, Litigation, Tax, Squire Patton Boggs, HM Revenue and Customs (UK)
    Authors:
    Rachael Markham
    Location:
    United Kingdom
    Firm:
    Squire Patton Boggs
    Re Avanti Communications Limited (in administration) - evolution of the control required for a fixed charge
    2023-05-17

    The High Court recently issued its ruling in the matter of Re Avanti Communications Limited (in administration). It is the first major case since the pivotal 2005 House of Lords decision of Re Spectrum Plus  to examine the characteristics of fixed and floating charges.

    Key points

    Filed under:
    United Kingdom, Insolvency & Restructuring, Litigation, Stephenson Harwood LLP, HM Revenue and Customs (UK), House of Lords
    Authors:
    Charlotte Drake , Aisha Ayanbunmi , James Linforth , Nick Axup
    Location:
    United Kingdom
    Firm:
    Stephenson Harwood LLP
    Navigating financial insecurities - ten top tips
    2023-05-18

    The current economic landscape is presenting challenges for many businesses. Our restructuring and business advisory specialists have provided a list of ten top tips if your business is facing financial distress.

    The current economic landscape is presenting challenges for many businesses. Our team at Shepherd and Wedderburn is here to help you navigate those challenges.

    Adaptability and resilience have never been more important as many businesses are currently facing ongoing challenges, such as:

    Filed under:
    United Kingdom, Insolvency & Restructuring, Shepherd and Wedderburn LLP, Supply chain, Insolvency, HM Revenue and Customs (UK)
    Authors:
    Fiona McKerrell , Suzanne Knowles
    Location:
    United Kingdom
    Firm:
    Shepherd and Wedderburn LLP
    Re Great Annual Savings Ltd
    2023-05-18

    The judgment of Adam Johnson J in Re Great Annual Savings Company Ltd, (Re Companies Act 2006) [2023] EWHC 1141 (Ch) demonstrates again the rigorous approach the courts are taking in relation to the fulfilment of the conditions required to “cram down” dissenting creditors in restructuring plans as well as in the exercise of the court’s discretion to sanction them.

    Filed under:
    United Kingdom, Insolvency & Restructuring, Litigation, Tax, Wedlake Bell, HM Revenue and Customs (UK)
    Authors:
    Robert Paterson
    Location:
    United Kingdom
    Firm:
    Wedlake Bell

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