International debt restructuring: can other jurisdictions compete with London and New York?

GRR invited 10 cross-border insolvency practitioners in London. The only German roundtable participant was Ivo-Meinert Willrodt, a partner at PLUTA in Munich. He argued that it will be very difficult for the UK to continue „marketing“ its schemes to Europe in light of the recognition issues accompanying Brexit. Willrodt also pointed to a new business insolvency directive proposed by the EU, which would introduce harmonised restructuring rules including pre-insolvency procedures all around Europe. He also explained the situation in Germany. Some German companies have changed their COMI to take advantage of different domestic courts.