The sheer quantum of debt to be refinanced before 2016 is enormous. Many companies will face some form of balance sheet restructuring, the most common of which is the debt-for-equity swap. Accessing the ‘standard’ debt-for-equity exemption is less certain than it might at first appear. The definitional requirement can catch the unwary.
Meanwhile HMRC issued guidance in the summer of 2010 that highlighted their purposive interpretation, for instance in relation to holding period requirements. Finally the advent of IFRS and its convergence with UK GAAP can produce unexpected results that may need practitioners to recommend workarounds when advising on restructurings.
