A tide of looming debt maturities for businesses with limited restructuring options, together with pressure on banks to deleverage in order to meet increased capital ratio requirements, has created opportunities for investors seeking to acquire, hold, and in some cases, actively manage distressed debt for potentially enhanced returns arising from a possible ‘pull to par’ in asset values. Whilst market tendency has often been to use a non-UK vehicle to house the debt, offshore regimes having responded to calls for a relatively benign legal, tax and regulatory environment, UK vehicles ought no longer to be overlooked if seeking to achieve tax neutrality and efficient profit extraction for investors.
