English Tax Considerations for Schemes and Restructuring Plans

An analysis of tax implications arising under the UK tax system for the creditor schemes, particularly in relation to debt waivers and releases including debt-for-equity swaps. The chapter analyses the importance of a 'loan relationship' for purpose of UK corporation tax and how it affects the tax treatment in the context of creditor schemes. The chapter also analyses statutory reliefs from tax charges of a company that is subject to an insolvency procedure or which undertakes a Part 26 Scheme or a Part 26A Restructuring Plan. The chapter summarizes conditions for determining the existence of tax-free debt waivers, tax implications of a relationship existing between connected companies where the debtor and lender are connected, and tax reliefs available under debt-for-equity exchanges.