Whilst 2020 will be remembered for less positive reasons, restructuring professionals may remember it for the creation of: (i) the “Restructuring Plan” under the UK’s Corporate Insolvency and Governance Act 2020 (CIGA 2020); (ii) the Dutch scheme under Wet homologatie onderhands akkoord (Dutch Scheme); and (iii) the German scheme under the StaRUG (German Scheme). Each bears similarities with the tried and tested English scheme of arrangement but has adopted certain features from the US Chapter 11 process.
This article, which first appeared in the May 2021 issue of Butterworths Journal of International Banking and Financial Law covers some of the important differences between each process that practitioners should be aware of.
Click here to read the article in full.
Authored by James Maltby, Christine Borries, Dylan Goedegebuure, and Celine Buttanshaw.
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