Poll: the world’s best restructuring regime

Author: Ashley Lee | Published: 22 Jan 2015

IFLR asked sources to rate the leading global reorganisation regimes. Results suggest the UK has toppled the US as the restructuring hub of choice

Which regime is optimal for cross-border restructurings?
One of the most frequently predicted – and somewhat unwelcome – developments in the global financial markets this year is that US interest rates will rise. While it will reflect higher growth in the US, it means that companies globally may find it more difficult to refinance their debt. And those unable to refinance, may need to restructure.

The increasingly globalised economy means that restructuring regimes that can be applied to creditors worldwide are more essential than ever. While no single framework exists, the two most popular remain the UK scheme of arrangement and Chapter 11 of the US Bankruptcy Code. Those that use other processes rely on Chapter 15 of the Bankruptcy Code to be recognised in the US.

Both...