In this article Paul Pritchard, Managing Director of our European Tax Advisory team discusses how the deemed release rules apply to transactions in debt rights.
This is an extract from Tax Journal, first published on June 17, 2021. The whole publication is available at https://www.taxjournal.com/articles/-debt-restructuring-deemed-releases.
The impact of the pandemic may necessitate a financial restructuring of a companys liabilities. As part of the plan, steps to restructure external debts could be caught by the deemed release rules. For example, a distressed group buys back its debt at a discount to the amount of the liability owed, or the creditor company acquires or otherwise becomes connected with the debtor company. To mitigate ta…
Read the full article at: https://www.jdsupra.com/legalnews/debt-restructuring-deemed-releases-4373329/