GLOBAL RESTRUCTURING TRENDS - #ACTNOWTORECOVER #ACTNOWTOGROW #VALUECREATION NOVEMBER 2021 - PWC
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As economies begin to emerge from the turmoil of the COVID-19 pandemic, our report explores the challenges facing businesses and the road ahead in 46 markets worldwide.
Contents Restructuring Trends: A Global View Italy 47 Executive Summary 1 Japan 48 One: Brakes on restructuring coming off 2 Kenya 49 Two: Uneven road to recovery 5 Malaysia 51 Three: Supply chain disruption and inflationary pressures 7 Mauritius 53 Four: Transformation gathers pace 9 Mexico 55 Five: Expanding restructuring toolkit 10 Middle East 57 Debt capital markets update 13 New Zealand 59 Themes by countries and regions Nigeria 61 Australia 19 Norway 62 Austria 20 Philippines 63 Belgium 21 Portugal 64 Brazil 22 Romania 65 Canada 23 Russia 66 Cayman Islands and British Virgin Islands 25 Serbia 67 China 27 Singapore 68 Croatia 28 South Africa 69 Czech Republic 29 South Korea 71 Denmark 31 Spain 73 Finland 32 Taiwan 74 France 33 Thailand 75 Germany 35 The Netherlands 77 Ghana 37 Turkey 79 Gibraltar 38 UK 81 Greece 39 USA 82 Hong Kong 41 Vietnam 83 India 43 Appendix Indonesia 44 Data references 85 Ireland 45 Contacts 89 This document includes data derived from data provided under license by Dealogic. Dealogic retains and reserves all rights in such licensed data.
Executive summary Foreword Welcome to Restructuring Trends 2021 Gearing up for transformation – a global view. As the focus shifts to recovery and growth, As economies begin to emerge from the turmoil businesses are looking at how to create value of the COVID-19 pandemic, our report explores in markets being reshaped by the acceleration the challenges facing businesses and the in digital transformation and growing road ahead in 46 markets worldwide. We also stakeholder focus on environmental, social and look at developments in insolvency legislation governance (ESG) issues. Heather Swanston and their implications for restructuring Global Business professionals, businesses and lenders. As disruption and change gather pace, the Restructuring central challenge for businesses is how to Services leader During the most acute phase of the pandemic, optimise their portfolio in the medium-to- PwC Japan many businesses were forced into survival long term rather than just short-term survival. mode, with revenues drying up and liquidity The extent of lender and other stakeholder under pressure. The lifeline of government support hinges on whether the business can relief, credit moratoria and huge availability generate long-term value in these evolving of capital at low interest rates helped many market conditions. The availability of finance companies weather the crisis. Restructuring will also be increasingly linked to strategy and insolvency activities were generally and performance on ESG and diversity and subdued as a result. inclusion, as outlined in our latest Act Now: From Recovery to Growth report. More recently, vaccine roll-outs have led to the lifting of restrictions and improvements It’s therefore important for all parties to in consumer and business confidence within understand how this medium-to-long-term many economies. But with opening up comes value will be generated. In line with our latest the scaling back of government support and Act Now research, four key priorities stand out: the need for businesses to tackle the debt burden accumulated during the pandemic. 1 Realigning operations Further challenges include the need to ramp 2 Bolstering liquidity and working capital up output in the face of continued strains on liquidity, rising raw material prices and mounting supply chain disruption. In turn, 3 Stepping up progress on corporate deleveraging progress on vaccination varies, leaving countries with low immunisation rates vulnerable to fresh surges in infection and 4 Optimising the business portfolio resulting lockdowns. The coming pages offer insights into Businesses around the globe have to navigate businesses’ ability to meet the immediate an asymmetrical recovery whilst looking ahead challenges and gear up for the transformational to the future and recovery from the pandemic. market developments ahead. During the most acute phase of the pandemic, many businesses were forced into survival mode, with revenues drying up and liquidity under pressure. 1 Global Restructuring Trends – November 2021
One: Brakes on restructuring coming off While the impact of the COVID-19 pandemic is receding, the coming year presents a fresh set of challenges as businesses deal with the withdrawal of government support and shift from stabilise and survival mode to longer term recovery and growth. Insolvency and restructuring have been subdued, but are expected to pick up as we move into 2022 and beyond Government relief and credit moratoria, support from banks and other lenders, and the huge availability of capital at low interest rates have largely held back insolvency and restructuring activity throughout the pandemic. Figure 1: Private PrivateDry Markets Markets Dry(USD Powder Powder 'bn) (USD ‘bn) 2000 332 2001 417 2002 457 2003 459 2004 472 2005 643 2006 909 2007 1,136 2008 1,229 2009 1,235 2010 1,149 2011 1,153 2012 1,117 2013 1,387 2014 1,380 2015 1,507 2016 1,681 2017 2,016 2018 2,356 2019 2,553 2020 2,841 Jun-21 3,297 0 500 1000 1500 2000 2500 3000 3500 Source: Preqin Insolvency and restructuring have been subdued, but are expected to pick up as we move into 2022 and beyond. Data sources are available on page 85 2
This combination of state support and Further risks include the high level of readily-available capital has made fiscal debt after many governments Priorities ahead amend-and-extend or refinancing the borrowed money to help support • Companies need to re-appraise and clear and preferred solutions in many businesses during the crisis. The shore up their liquidity and working situations to date. The abundance of debt burden means that the scope capital requirements to address the capital and pressure to put it to work for further state aid in the event of unwinding of government support mean that a lot of these refinancing fresh surges in infection could be and debts accrued during the agreements have been covenant-lite. limited. The risk is especially marked in pandemic, while at the same time Where there has been insolvency or countries where government debt was meeting renewed customer demand more comprehensive restructuring already high going into the crisis. This and delivering delayed investment. activity, it has tended to be either includes a number of major economies sector (e.g. those most affected by the such as France and Japan. • The likely limited availability of pandemic such as retail, hospitality further government support in some and travel or ESG-related such as in Some economies are already seeing economies will increase reliance on mining and energy) or situation specific a resulting uptick in insolvency existing lenders, shareholders and (e.g. fraud or businesses suffering from activity, particularly in the mid-market. access to the capital markets, which volatile commodity price and supply Activity could accelerate even faster may be less forthcoming in sectors chain issues). in less developed markets where there where the prospects for recovery is less resilience and low COVID-19 and long-term growth are less clear. However, the extent of government immunisation rates could hamper relief has varied. Some countries, recovery and heighten the dangers such as Mexico, have held back on of a renewed wave of infections. government stimulus amid continuing However, in most markets there will austerity. Others may have wanted to be a lag, though we would expect inject more support, but have been to see a step-up through the course constrained by elevated levels of of 2022. At the other end of the sovereign debt going into the crisis. spectrum, exceptionally rapid recovery The abundance of In turn, even with government relief, and plentiful capital for refinancing some economies such as Turkey and may prevent any significant surge in capital and pressure Hong Kong have seen high levels of insolvency even during the pandemic. insolvencies in some markets such as the US. to put it to work As government support measures Businesses at the centre of the mean that a lot of start to be withdrawn and temporary restructuring radar include those in these refinancing loans come due for repayment, the sectors most severely affected by brakes on insolvency and restructuring lockdowns and travel restrictions agreements have activity will begin to come off. Over- including tourism, airlines, hospitality leveraged capital structures will need and bricks-and-mortar retail. Other been covenant-lite. to be addressed and maintaining focus areas include sectors already lender forbearance and support feeling the impact of the move to Net could also become more challenging, Zero such as mining and energy as well particularly in sectors where the as those experiencing growth pains as prospects for recovery and long-term they emerge from the pandemic (spikes growth are less clear. in demand, supply chain issues, labour shortages, commodity price volatility Some countries, such as Malaysia and and inflation). Greece, are expecting an offloading of non-performing loans by banks to special situation funds which in turn may drive a more aggressive approach to recovery. In addition some markets are seeing an influx in non-bank lenders for the first time, such as New Zealand. 3 Global Restructuring Trends – November 2021
Figure 2: Government support as a % of 2020 Real GDP 24% 12% 37% 16% 8% France Germany Italy UK China 23% 31% 5% 36% 12% Canada USA Russia Japan Hong Kong As government support measures start to be withdrawn and temporary loans come due for repayment, the brakes on insolvency and restructuring activity will begin to come off. Data sources are available on page 85 4
Two: Uneven road to recovery Focus is shifting from survival In addition, whilst consolidation in and stabilise to recovery and some sectors has been seen to date, Priorities ahead growth. more is expected through further M&A • In this uncertain and potentially activity as players start to capitalise on stop-start pathway to recovery and While the momentum for global growth opportunities. growth, it’s essential to monitor economic recovery is gathering overall, cash and develop realistic forecasts the pace looks set to vary between In economies where the rebound is which take account of potential countries and sectors. furthest forward, the business focus varying recovery scenarios. is moving from short-term survival One key factor is progress on to recovery and growth, bringing • The immediate demands don’t just vaccination. While rates tend to be with it challenges in managing the include day-to-day expenses, but lower in poorer countries, a number of associated demands on liquidity and also funding for future growth and advanced economies are also lagging. working capital. to adapt to the trends reshaping marketplaces and economies. The speed of recovery within and The speed of the rebound in some between sectors also differs quite economies and resulting surges markedly. Airlines and tourism will in demand could further stretch take time to get back to pre-pandemic resources. And as digital disruption levels, particularly in economies where and expectations on ESG threaten there are continuing travel restrictions to turn whole sectors on their head, affecting tourism businesses such as companies face the challenge of Australia, Japan and New Zealand. adapting business models, securing the funding needed to finance the necessary transformation and, Other sectors such as hospitality and ultimately, boost value over the retail may come back more quickly as medium-to-long term. restrictions ease – for example in the US, many such service enterprises are already bouncing back and even exceeding pre-pandemic levels in some cases. Airlines and tourism will take time to get back to pre-pandemic levels, particularly in economies where there are continuing travel restrictions affecting tourism businesses such as Australia, Japan and New Zealand. 5 Global Restructuring Trends – November 2021
Real 3:GDP Figure Real growth / decline GDP growth / decline 2020 2020 – –Annual Annual percent percent changechange no data Less than -3% -3% – 0 0 – 3% 3% – 6% 6% or more Real Figure GDP 4: Realgrowth / decline GDP growth / decline2021 2021 ––Annual Annual percent percent change change no data Less than -3% -3% – 0 0 – 3% 3% – 6% 6% or more Data sources are available on page 85 6
Three: Supply chain disruption and inflationary pressures Supply chain disruption could Supply chain issues put further hold up recovery and jeopardise pressure on working capital and Priorities ahead some businesses. emphasise the need for resilient supply • New COVID-19 variants remain a chain management. For economies as threat to the pace and extent of From steel to semiconductors, supplies a whole, the pincer of impaired output economic recovery, both through of raw materials and finished goods, and rising inflation could slow or even the risk of further lockdown and along with the capacity to transport derail recovery. in heightening the potential for them, are under pressure or seeing a supply chain disruption for many significant rise in prices. Alongside supply chain bottlenecks, businesses. Supply chain resilience resurgent demand is adding to is therefore essential, especially in Severely affected sectors include shortages of key skills. We’ve already the most affected sectors such as construction, where disruption is seen how travel restrictions have construction and automotive. causing project delays and pressure on curtailed the movement of seasonal costs and cash flows. In turn, a number staff – from crop pickers to hospitality • Dealing with talent shortages of automotive manufacturers have had workers. We’ve also seen how many requires long-term planning as well to curtail or temporarily shut down workers in shutdown sectors such as short-term plugs. Pay, conditions production altogether because of the as hospitality have taken up jobs in and prospects may all need to shortage of semiconductors. other industries and seem unlikely to be improved. Action to improve return. Longer term issues include diversity could in turn enlarge talent the shortage of commercial drivers pools and help to attract higher In addition the recent increase in worldwide, with often poor conditions, quality recruits. wholesale gas prices in Europe has had lack of diversity and an ageing an adverse impact on the energy retail workforce continuing to diminish an sector and is likely to lead to further already shrunken talent pool and supply chain pressures. making it hard to attract new recruits. Rising raw material prices are also Some of the talent shortages heightening inflationary pressures, may be temporary, especially as which may translate into interest restrictions on movement are eased. rate rises in due course. Among But pay rates may also need to rise the prominent markets where rising quite markedly to attract scarce talent, inflation may be met with an increase in which could in turn add a further spur base rates is the UK, where there is still to rising inflation. the possibility that rates may rise later this year rather than next year. From steel to semiconductors, supplies of raw materials and finished goods, along with the capacity to transport them, are under pressure or seeing a significant rise in prices. 7 Global Restructuring Trends – November 2021
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Four: Transformation gathers pace Need to keep pace with digital Further considerations for businesses transformation and expectations in all sectors include how their strategy Priorities ahead on ESG and diversity and and performance will rate from an ESG • The big question for companies perspective. Our UK Act Now report as they look to future-proof their inclusion. highlights the growing importance strategy and capabilities is where of ESG in credit and investment to direct often limited financial The acceleration in digital decisions. Businesses with no viable resources when there is so much transformation in many sectors as ESG strategy could find it increasingly pressure to change on so many a result of the pandemic opens up difficult to secure financing. fronts. Operational modernisation, increased opportunities for innovation and growth on the one side, while ESG and diversity and inclusion Even in economies that are currently are all likely to require significant making some operations and even dependent on oil and gas, the focus on investment. Companies will whole companies unviable on the other. decarbonisation and the development need to factor in the impact of of alternative opportunities is clear. implementing such changes Operational restructuring is needed to The Gulf states, for example, face into their consideration of the modernise capabilities and streamline pressure to play their part in tackling appropriate capital structure and operations, as some sectors have seen climate change. There is also domestic funding requirements. wholesale structural change in recent pressure for change as a result of years with this only set to continue. the volatility in fossil fuel markets in • Careful planning and prioritisation recent years and resulting economic are essential now that ESG Divestment of noncore and instability. In line with these trends, and diversity and inclusion are underperforming operations is enabling the Saudi Tadawul and Qatar Stock weighing ever more heavily on businesses to refocus resources on Exchange (QSE) are racing to launch credit decisions. This presents recovery, transformation and growth. ESG indices in 2021, following Dubai opportunities as well as challenges. Financial Market’s early lead with the For example, we’re seeing a growing ESG’s move to the centre of the 2020 launch of the S&P/Hawkamah number of financing arrangements strategic agenda presents comparable ESG UAE Index. linked to ESG targets, KPIs and challenges and opportunities. This is a chance for businesses to regenerate information and monitoring Just like ESG, diversity and inclusion requirements. the environment, create fairer societies are having a growing impact on and build greater trust with customers, stakeholder perceptions and financing employees and policymakers. But decisions. Our latest Act Now research perhaps more importantly this is a has found that nearly 60% of UK huge commercial opportunity. In investors are more likely to extend automotive, for example, the potential financing in a company with a diversity is highlighted by the take-off in electric and hybrid vehicle sales in 2020 and and inclusion policy. Again this is Even in economies more than a tick-box exercise. For 2021, following a decade of steady but example, sectors suffering some of that are currently unremarkable growth. The challenges include how quickly carmakers can the severest talent shortages such as technology, construction and dependent on oil accelerate the transition away from petrol and diesel vehicles, not just in logistics are also among the least and gas, the focus diverse. More women and others from production, but by making electric models sufficiently affordable within under-represented groups within the on decarbonisation workforce would help to bridge these the mass market. talent gaps. It would also help these and the development sectors to better understand changing consumer demands. of alternative opportunities is clear. 9 Global Restructuring Trends – November 2021
Five: Expanding restructuring toolkit Legislation and innovation are One of the key considerations for improving the speed, choice lenders where legislation is more Priorities ahead and flexibility of restructuring debtor-friendly, such as the new UK • It’s important for companies to Restructuring Plan, which includes determine which tools best serve options / solutions. the ability to cram down dissenting their purposes, and consider creditors across classes, is how to whether they can access more The expected uptick in restructuring be on the front foot in challenging favourable options outside those is coinciding with the introduction of such proceedings. What has become available in their local territories. useful new options and the removal of clear from recent cases, is that it many of the barriers that have held up will be key for lenders to have an • Businesses may look to use proceedings in the past. implementable alternative plan and as legislation to help tackle some of such early engagement with the debtor the issues emerging from the crisis, An extensive list of recent developments and access to information will be including to potentially restructure includes the new UK Restructuring Plan increasingly important. excessive fiscal debt arising from and Dutch ‘scheme’ (WHOA), as well as new legislation in Germany, Belgium, COVID-19 related support. Lenders Ireland, Greece, Brazil, India, the UAE will need to be on the front foot and KSA. We’ve also seen Hong Kong in challenging such proceedings, benefiting from greater cooperation particularly where these are more with courts in Mainland China and debtor-friendly. the Cayman Islands are awaiting the implementation of a formal restructuring regime for the first time. 10
Global vaccination progress as of 20 October. Fully vaccinated % Partly vaccinated % Australia 58 14 3 Austria 61 1 Belgium 73 Brazil 50 23 7 British Virgin Islands 51 5 Canada 73 0 Cayman Islands 84 5 China 71 3 Croatia 43 1 Czech Republic 56 1 Denmark 76 8 Finland 67 8 France 67 3 Germany 65 3 2 Ghana 0 Gibraltar 100 2 Greece 61 3 Hong Kong 57 India 21 30 Indonesia 23 16 1 Ireland 75 6 Italy 70 8 Japan 69 2 4 Kenya 11 Global Restructuring Trends – November 2021
Fully vaccinated % Partly vaccinated % 6 Malaysia 71 4 Mauritius 65 Mexico 40 14 New Zealand 59 15 1 1 Nigeria 9 Norway 68 9 Philippines 19 2 Portugal 87 5 Romania 30 3 Russia 32 2 Serbia 42 1 Singapore 79 6 Saudi Arabia 59 5 South Africa 18 2 South Korea 67 2 Spain 79 Taiwan 24 40 17 Thailand 36 10 The Netherlands 68 9 Turkey 59 9 UAE 86 6 UK 67 9 USA 56 Vietnam 19 29 Data sources are available on page 85 12
Debt capital markets update Debt capital market trends 13 Global Restructuring Trends – November 2021
The debt capital markets have Borrowers have been able to in general rebounded strongly take advantage of the favourable from COVID-19. The favourable environment to refinance existing financing environment, coupled loans and bonds at lower cost with extended maturities. Refinancing Borrowers have with various government support measures, have allowed and repricing deals in loan markets been able to accounted for over 60% of overall loan companies to survive the issuances in the run up to September take advantage pandemic. Looking forward, the 2021, while refinancing represented favourable conditions are now over 70% of overall activity in the high of the favourable poised to help recovery and yield bond market. environment to growth ahead. The leveraged finance markets were refinance existing strong in the first quarter of 2021, We however see exceptions in APAC, particularly China, where the default primarily driven by the refinancing and loans and bonds repricing deals mentioned earlier. The of Evergrande and a number of other market pace cooled slightly in Q2 and at lower cost with property developers have substantially dampened the mood of the market. Q3, as the market started to shift from refinancing and repricing to new money extended maturities. Whether there will be wider economic deals. Along with this slight market repercussions remains to be seen. cooling, lenders and investors were able to firm up pricing where margins In addition the ability of businesses to ticked back up slightly from the lows access this financing will be dependent of Q1. on a number of factors, such as the future prospects of the sector they Looking forward, the leveraged operate in and the impact of ESG financing markets in America look considerations. on track for a strong H2 2021. The fundamentals point to robust lender Americas and investor appetite supporting solid The leveraged loan (LL) and high yield demand as the economy continues to bond (HYB) markets in Americas have open up, albeit subject to deal specific rebounded from the pandemic-driven considerations and challenges such lows of Q1 and Q2 2020. as overall sector prospects. Leveraged loan issuances for the period ending September 2021 climbed to $1,291 billion, up 32% from $976 billion over the entire of 2020 while high yield bond issuances reached 93% of the total issuance last year. America Figure 5: Americas – High Yield Bonds and Leveraged Loan Issuance (USD ‘bn) High Yield Bonds and Leveraged Loan Issuance (USD 'bn) 2015 254 1,038 1,293 2016 301 1,259 1,561 2017 355 1,723 2,077 2018 189 1,592 1,781 2019 285 1,236 1,521 2020 449 976 1,425 2021 419 1,291 1,710 Q3 YTD 0 500 1000 1500 2000 2500 USD ('bn) High Yield Bonds Leveraged Loans Copyright © 2021, Dealogic Limited. All rights reserved. Data sources are available on page 85 14
EMEA Figure 6: EMEA – High Yield Bonds and Leveraged Loan Issuance (USD ‘bn) EMEA High Yield Bonds and Leveraged Loan Issuance (USD 'bn) 2015 131 376 507 2016 125 373 498 2017 181 503 685 2018 113 425 538 2019 151 377 528 2020 148 377 525 2021 170 357 527 Q3 YTD 0 100 200 300 400 500 600 700 USD ('bn) High Yield Bonds Leveraged Loans Copyright © 2021, Dealogic Limited. All rights reserved. EMEA HYB Issuance this year has shifted Both the leveraged loan and high from double-Bs to single-Bs, providing yield bond markets in EMEA have evidence that investors are willing to rebounded strongly from the initial impact of COVID-19. Issuance in support credits that despite being financially weaker, have a clear The clear the first three quarters stands at pathway to recovery. TUI, Douglas recovery has been $527 billion, which is higher than the and Golden Goose are examples of entirety of 2020 issuance. disrupted businesses able to obtain driven largely by liquidity from the HYB market and The clear recovery has been driven attract strong investor interest. M&A activity, usually largely by M&A activity, usually an indicator of bullish markets. This Meanwhile sustainability linked an indicator of accounts for around 50% of activity loans and bonds have surged bullish markets. this year so far. Notable deals include: in popularity this year with both borrowers and investors. • €1.115 billion raised by EQT to facilitate to public-to-private deal of Following Public Power Corporation’s Sweden’s Recipharm inaugural sustainability-linked HYB • €600m & $547 million dual- issuance, we saw the first HYB buyout tranche term loans for the Bain-led deal which included sustainability consortium for the acquisition of linked language. Lonza Speciality Ahistrom-Muksjo; and Ingredients, a Swiss provider of • €660 million term loan to specialty chemicals for microbial support Apax Partners’ buyout control solutions, issued a some €290 of Rodenstock million 7NC3 tranche and a some €380 million 8NC3 tranche priced at 4.75% and 5.25% respectively, backing its carve-out by Bain and Cinven. The sustainability-linked bond will include a 25bps step-up per annum, starting on 25 May, unless certain sustainability performance targets are met. 15 Global Restructuring Trends – November 2021
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Asia Figure 7: Asia – High Yield Bonds and Leveraged Loan Issuance (USD ‘bn) High Yield Bonds and Leveraged Loan Issuance (USD 'bn) 2015 57 303 360 2016 90 334 424 2017 117 348 465 2018 91 272 363 2019 149 280 429 2020 127 241 368 2021 84 205 289 Q3 YTD 0 100 200 300 400 500 USD ('bn) High Yield Bonds Leveraged Loans Copyright © 2021, Dealogic Limited. All rights reserved. Asia Meanwhile, in the Southeast Asia Furthermore, issuers with debt Compared with its counterparts in and South Asia markets, the US maturing in the immediate short-term the Americas and EMEA, markets in Dollar denominated high yield and LL are likely to take advantage of the Asia have been relatively quiet this issuances have recovered to a healthy liquidity rich environment to refinance year. HYB issuance only amounted level, with strong traction shown in the their liabilities, sooner rather than to $84 billion, representing 66% of first three quarters of 2021. later, to benefit from the low interest the 2020 total. This is mainly due to rates. However, the Delta variant and the muted activity by Chinese real Majority issuance contributions in low vaccination rates continue to estate developers, who historically the region came from the Philippines, pose a recovery obstacle and hence dominated the USD HYB market. Indonesia and Singapore. Some of the investors are expected to be naturally Indeed, according to Debtwire data, largest deals includes Singaporean real more selective. the volume of HYB issuance is now at estate logistics provider GLP, which its historic low. raised $850 million priced at 4.5%, Finally, the themes of impact investing Golden Energy & Resources Ltd, which and ESG are becoming an increasing The default by Tahoe Group, a Chinese raised $285 million priced at 8.5% and focus due to an accelerating developer, in January 2021, started ABM Investama Tbk PT which raised awareness of the institutional investors. heightening investor concerns. There $200 million priced at 9.5%. More future debt issuances with such have been subsequent defaults by a themes are to be expected. number of other high-profile names in For the South Asia region, high yield the market – China Fortune Land, PK bond issuances in India are a large There has been an increasing trend in Founder and TUS, Sichuan Languang, driver. Most of these issuances have the Asian markets for private debt. The and even Evergrande, the largest been green and sustainable bonds. Preqin 2021 Private Debt Global Report developer in China. Notable issuers included Indian noted that 44 private debt funds (up hydropower producer JSW Hydro from 38 in 2020), comprising an AUM Nonetheless, the market has not Energy, which raised $707 million of about $11 billion, are now focused completely frozen, with a couple of priced at 4.12% and Shriram Transport on Asia. Notable funds include the issuances by smaller developers albeit Finance Co Ltd, which priced a $500 PAG Loan Fund IV ($1.5 billion) and at relatively high prices. These include million MTN priced at 4.4%. Edelweiss Special Opportunities Fund Fujian Yango’s $250 million 12.5% III ($900 million), which are both direct due 2024s, and China Aoyuan’s $200 In both these markets, one lending funds. million 8.25% 3NC2. noticeable trend is that the issuers are mostly familiar names that have Developed markets, such as North issued debt frequently over the years. America and Europe, are becoming Investors are well-versed with these increasingly saturated, with risk- frequent issuers and their transparency return profiles that do not correspond has increased the chances of a with what investors desire. Hence, successful debt issuance. more institutional attention is turning towards Asia. 17 Global Restructuring Trends – November 2021
Themes by countries and regions 18
Australia Insolvencies are at record lows, Repayment pressure though this could change once From mid-2021, there were signs that economic normality returns and some key creditors (including the government support recedes. Australian tax office and landlords) were 2020 Real looking to take steps to recover long GDP (USD bn) Australia has bounced back from its overdue debts. However, the return of lockdown is likely to be met with renewed $1,543 first recession in nearly 30 years, which occurred as a result of COVID-19 in concessions and/or a halt to proactive 2020. Unemployment and interest rates recovery actions until 2022. Major are trending toward all-time lows and lenders continue to provide significant consumer and business confidence accommodation to distressed companies is high. in the form of covenant waivers and principal and interest deferrals. Insolvency activity has remained at Real GDP Total unemployment historic lows. This reflects the ongoing Restructuring climbs back in 2022 growth/(decline) growth/(decline) short – to medium-term support from We expect restructuring and insolvency both the public and private sectors, activity to pick-up in 2022. Vaccination GDP YoY 2009 2009 1.7% rates will have hit targeted levels. This 21.9% which has propped up balance sheets. will start the move toward some form of However, a rise in COVID-19 Delta variant economic normality, and resulting scaling infections has recently led to a fresh back of government support. GDP YoY 2020 2020 (2.4%) 30.3% round of lockdowns in most major cities. Government support is also less certain Major creditors are likely to focus on or abundant compared to last year. recoveries, while spending patterns of Australians will likely change materially as GDP YoY 2021 2021 The ability of businesses to withstand the latest challenges will likely become evident in early 2022. international borders open and consumer dollars are spent further afield. This will create winners and losers. 4.2% (10.3%) 2022 Stabilising balance sheets Many listed companies affected by the pandemic moved quickly to raise fresh So far, the bulk of restructuring activity has been in sectors going through (13.3%) equity in mid-2020, which has generally structural or regulatory change (e.g. given them the necessary buffer to Aged Care) and businesses impacted withstand new lockdowns. by ESG developments (including mining and energy) or those most Further support has come from the impacted by the pandemic (e.g. tourism, CPI Average ‘JobKeeper’ programme, which has hospitality, events) Several of the largest lending rate enabled many businesses in various restructurings in the past 12 months have industries (including retail) to accumulate not been directly linked to COVID-19, but 2020 2020 0.9% 3.7% material cash reserves. However, rather have been situational (e.g. fraud) or these will be tested during the current sectoral (e.g. ESG). lockdowns, which are expected to continue until the back end of 2021. 2021 2021 2.7% 3.7% Australia Government support as a % of 2020 Real GDP Vaccination progress as Status of COVID-19 at 20 of October* vaccinations: 2022 2022 3.0% 3.6% Australia 19% 14% 58% No. of insolvencies 5,000 Share of total population fully vaccinated against Fully vaccinated COVID-19 Partly vaccinated No. of insolvencies Share of total population only partly vaccinated 4,000 against COVID-19 3,000 *Country data may have been provided on a different date. 2,000 PwC Local contact 1,000 Stephen Longley 0 T: +61 414 921 241 Q1 2019 Q2 2019 Q3 2019 Q4 2019 Q1 2020 Q2 2020 Q3 2020 Q4 2020 Q1 2021 Q2 2021 E: stephen.longley@pwc.com 19 Global Restructuring Trends – November 2021
Austria Insolvencies are set to rise as Restructuring gathers pace government relief recedes, but there We expect an increase in restructuring will be no surge. Pressure is not just as state support decreases. A number of coming from rising debt, but also the companies in the sectors hit most from 2020 Real need to finance growing demands on the pandemic, such as entertainment, GDP (USD bn) digital transformation and ESG. travel and store retail, will find it hard $419.2 to service debt (including deferred Since the start of the pandemic, tax), necessitating both financial and insolvencies have decreased to operational restructuring. historically low levels. As of Q2 2021, the number of cases has picked up slightly, Pressure may increase if the recovery but is still more than 50% below pre- stalls. Risks include infection rates pandemic levels. higher than last year as we move into the winter months. Real GDP Total unemployment However, some of the relief measures growth/(decline) growth/(decline) that have held back insolvencies are now The specific trends that are likely to coming to an end. Monthly tax and social trigger restructuring include: GDP YoY 2009 2009 (3.8%) 29.6% security payments can still be deferred for periods prior to 30 June 2021, but no • Repayment of deferred tax and social longer for new tax liabilities and social security contributions security contributions. At least 40% of • Need to build up working capital to GDP YoY 2020 2020 the deferred liabilities have to be repaid within 15 months. These repayments are likely to trigger a number of insolvencies. reboot operations • Capital expenditure backlog from 2020 (while there are state incentives (6.6%) 42.8% GDP YoY 2021 2021 A big wave is, however, not expected. of up to 14% of total expenditure, Business focus Businesses have focused on cost underperforming businesses may still find it hard to invEst) • Acceleration in digital transformation 3.0% (20.3%) 2022 reduction and cash management (e.g. by well-performing businesses reduction of working capital and initial delay of capital expenditure). Even more put additional stress on distressed companies (6.1%) important has been securing government • Increasing impact of ESG on credit support, such as deferred payment of decisions by banks. Underperforming tax and social security contributions businesses are likely to require and support for short time work. Due to external funds to pay deferred tax, cash incentives for capital expenditure bolster working capital and increase CPI Average (up to 14% for environmentally-friendly capital investment. But if they have yet lending rate investments and digitisation), we’ve seen to develop a viable strategy for ESG a lot of investment since the end of 2020. and digital transformation, lenders 2020 2020 may be reluctant to supply credit. 1.4% No data available Austria 2021 2021 Government support as a % of 2020 Real GDP Vaccination Status ofprogress COVID-19asvaccinations: at 20 of October* 1.7% No data available 2022 2022 2.0% No data available Austria 16% 3% 61% No. of insolvencies 2,000 Share of total population fully vaccinated against Fully vaccinated COVID-19 Partly vaccinated No. of insolvencies Share of total population only partly vaccinated 1,500 against COVID-19 1,000 *Country data may have been provided on a different date. 500 PwC Local contact 0 Q1 2019 Q2 2019 Q3 2019 Q4 2019 Q1 2020 Q2 2020 Q3 2020 Q4 2020 Q1 2021 Q2 2021 Manfred Kvasnicka T: +43 676 8337 72937 E: manfred.kvasnicka@pwc.com Data sources are available on page 85 20
Belgium While restructuring activity is low For many businesses, the focus now, it’s set to gradually increase remains on liquidity either due to pre- in the next six to 18 months as the existing problems or as a result of the effects of government support economic impact of the pandemic. 2020 Real wear off. As the economy rebounds, additional GDP (USD bn) liquidity is also being sought to sustain $551.4 The economy is rebounding strongly recovery and growth. (projected 4.7% growth in 2021), but could begin to soften in 2023. Another challenge that will occur for many companies is solvency. According Bankruptcies decreased by 32% in to the National bank of Belgium, 85% 2020, mainly as a result of government of non-financial corporations rated as measures. These include a moratorium solvent before the crisis and this is now on bankruptcies filed by third-parties and less than 75%. Real GDP Total unemployment two guarantee schemes for new credit growth/(decline) growth/(decline) lines provided by lenders. However, with Furthermore, recently we have seen government support ending and working an increased impact of the global GDP YoY 2009 2009 (2.0%) 13.8% capital demands rising again, we expect semiconductor shortage and other that restructuring activity will start to supply chain issues in a variety increase in 2022. of sectors, leading to significant business disruptions. GDP YoY 2020 2020 Business challenges The main challenge since the beginning of the pandemic has been a shortfall Restructuring flexibility In March 2021, the government enacted (6.3%) 3.8% GDP YoY 2021 2021 in liquidity. This applies to 23% of all a revision of the Procedure of Judicial businesses in Belgium and up to 45% of those in the hardest-hit sectors. Reorganisation (PJR). This aims to provide more flexibility in the necessary 4.7% 16.1% documentation and the timing when 2022 applying for PJR. The new legislation also (3.2%) Non-performing loan rates confirm that the three sectors that have suffered introduces the possibility for mediation most are hospitality, whole and retail before entering a public procedure that trade and construction. bears the risk of losing partners’ trust. Belgium CPI Average Government support as a % of 2020 Real GDP Vaccination progress Status of as 20 COVID-19 of October* vaccinations: lending rate 2020 2020 0.4% No data available Belgium 15% 1% 73% 2021 2.1% 2021 No data available No. of insolvencies 2022 2022 5,000 No. of insolvencies 4,000 Share of total population fully vaccinated against FullyCOVID-19 vaccinated Partly vaccinated Share of total population only partly vaccinated 2.6% No data available against COVID-19 3,000 2,000 1,000 0 Q1 2019 Q2 2019 Q3 2019 Q4 2019 Q1 2020 Q2 2020 Q3 2020 Q4 2020 Q1 2021 Q2 2021 *Country data may have been provided on a different date. PwC Local contact Thomas Deryckere T: +32 474 78 04 59 E: thomas.deryckere@pwc.com 21 Global Restructuring Trends – November 2021
Brazil Insolvency action is set to increase as An increase in the number of the enduring impact of the pandemic insolvency proceedings is expected becomes clear and companies take due to the pandemic, but as of June, stock of their position and prospects. there were fewer bankruptcy filings 2020 Real in 2020/2021. The expectation is that GDP (USD bn) COVID-19 hit as Brazil was still recovering insolvency cases will increase next year. $2,268.5 from its 2014-16 recession. Economic The government has already begun to recovery remained weak. Fiscal policy wind down support measures. By 2022, options have also been limited since the the economic effects of the pandemic peak of the recession in 2015-2016, with will be better understood by companies. GDP growth below 2% in the following As a result, they may decide that filing years. While recovery is broad-based for bankruptcy or other insolvency globally and across economic sectors, proceedings will help their businesses. serious challenges stand out. For Brazil, Real GDP Total unemployment the most important right now is the Improved mechanisms growth/(decline) growth/(decline) uneven struggle to control the pandemic. New insolvency legislation came into force in January 2021. This improves GDP YoY 2009 2009 (0.1%) 18.5% However plans to ensure that all of the mechanisms available to debtors the population receives at least one in court-approved restructurings vaccination dose by the end of 2021 and liquidations, including debtor-in- are now well underway. If immunisation possession lending and bankruptcy sale GDP YoY 2020 2020 proceeds at this accelerated rate, a broader reopening of the economy in H2 2021 and a ‘normalisation’ toward the of assets. The bulk of restructuring activity has (4.1%) 11.8% GDP YoY 2021 2021 end of the year could be possible. been in sectors suffering from the Taking stock pandemic, especially the service sector. Also in the frame are sectors affected 4.7% 2.2% Restructuring activity was limited in the by ESG developments, including mining 2022 first months of the pandemic. To contain and energy. the pandemic, Brazil implemented social measures to slow the spread of (2.8%) the virus and contain its impact on the health system, which is uneven across the country. CPI Average lending rate Brazil 2020 2020 Government support as a % of 2020 Real GDP Vaccination Status ofprogress COVID-19as vaccinations: at 20 of October* 3.2% 27.9% 2021 2021 7.9% 36.5% 18% 23% 50% 2022 6.9% 2022 52.6% Share of total population fully vaccinated against Fully vaccinated COVID-19 Partly vaccinated No. of insolvencies – No data available Share of total population only partly vaccinated against COVID-19 *Country data may have been provided on a different date. PwC Local contact Tatiana Guerra T: +55 11 3674 2480 E: tatiana.guerra@pwc.com Data sources are available on page 85 22
Canada The prospects for the economy Business insolvency activity also remain strong overall and insolvencies remains low. In the 12 months to June 30, are still at low levels, but recent 2021, business bankruptcy and proposal experience points to bumps in the proceedings were 22.2% below the prior 2020 Real road ahead. 12-month period. GDP (USD bn) $1,849.4 GDP is projected by most analysts to This reduced activity is primarily grow by around 5.9% in 2021. Business attributable to stimulus measures, confidence in August 2021 reached its forbearance by lenders and abundant highest level since 2006, with plans for capital. We’ve seen a willingness among capital spending starting to increase. lenders to provide covenant relief and waivers to borrowers, and generally defer However, GDP actually fell 0.3% in taking actions that would require more Q2 2021, affected in part by supply drastic restructuring measures. Five of Real GDP Total unemployment chain disruptions, a drop in exports, the six largest Canadian banks partially growth/(decline) growth/(decline) and softening residential investment. reduced their loan loss provisions in the Consumer confidence and business most recent quarter, reversing amounts GDP YoY 2009 2009 (2.9%) 36.9% prospects will be strongly affected by the recorded earlier in the pandemic as a extent of the fourth wave’s impact and result of their growing optimism on the the measures taken to limit its spread, economic recovery. In turn, liquidity is though the country’s high vaccination readily available for bankable businesses GDP YoY 2020 2020 (5.3%) 68.3% rate gives it a strong level of protection. where needed, and even troubled loans are being refinanced. Our conversations with banks and GDP YoY 2021 2021 business leaders indicate that while Prospects hard to call the overall economic outlook remains optimistic, concerns around rising inflation rates have become a reality. Restructuring and insolvency activity has grown in the oil and gas, mining and manufacturing sectors. We expect 5.9% (19.8%) 2022 Businesses have also commented on the to see further activity in the hospitality shortage of qualified staff and the rising cost of capital goods as factors affecting and leisure sector as stimulus measures expire, as well as in sectors affected by (15.1%) their investment plans. supply chain considerations such as the automotive sector. All of this activity will Many companies continue to face depend heavily on fiscal policy measures challenges anticipating post-pandemic taken by the federal government levels of demand, and dealing with the following the September 2021 election, CPI Average challenges to their supply chains that including interest rate movements and lending rate the pandemic brought on, which will possible further stimulus measures, as take time to resolve. Given the K-shaped well as the response to the fourth wave of 2020 2020 0.7% 2.7% recovery seen in Canada, some sectors the pandemic. (such as hospitality and leisure) have fared worse than others and will take Looking ahead, domestic insolvency and restructuring activity is hard to predict at 2021 2021 more time to get back on track. Restructuring activity still low Restructuring activity has remained present. Most recent cases have arisen due to idiosyncratic events affecting borrowers. We are monitoring a number 2.5% 2.0% 2022 2022 relatively low following an early flurry of of potential cases in the oil and gas, filings as the pandemic first took hold. manufacturing and automotive sectors, particularly given ongoing supply chain challenges, but the Canadian economy 2.1% 2.0% For the six month period to June 30, 2021, there were a total of 17 remains robust overall and has seen restructuring proceedings commenced significant M&A activity through the under the Companies’ Creditors pandemic. We anticipate that an increase Arrangement Act (CCAA), compared to in restructuring activity is likely in 2022, 46 in the same period in 2020. Most of as inflationary pressures continue to these cases arose from idiosyncratic affect demand, and as existing stimulus events, though the bulk of the filings programs start to wind down. occurred in the manufacturing and mining/oil and gas sectors. Privately-held companies made up all but one of the CCAA filings in the period. 23 Global Restructuring Trends – November 2021
Canada Government support as a % of 2020 Real GDP Vaccination progress Status of as at COVID-19 20 of October* vaccinations: 5% Canada 23% 73% No. of insolvencies 2,000 Share of total population fully vaccinated against FullyCOVID-19 vaccinated Partly vaccinated No. of insolvencies Share of total population only partly vaccinated 1,500 against COVID-19 *Country data may have been provided on a different date. 1,000 PwC Local contact 500 Greg Prince 0 T: +1 416 814 5752 Q1 2019 Q2 2019 Q3 2019 Q4 2019 Q1 2020 Q2 2020 Q3 2020 Q4 2020 Q1 2021 Q2 2021 E: gregory.n.prince@pwc.com Data sources are available on page 85 24
Cayman Islands and British Virgin Islands While formal restructuring has been Informal activity Cayman Islands subdued, refinancing has continued The highly globalised nature of the outside these structures and we work in the jurisdictions has meant expect more formal and informal that the offshore insolvency market activity over the coming year. has generally followed the direction of major global financial centres, such 2020 Real as London, New York, Dubai and GDP (USD bn) With the Cayman Islands and British Virgin Islands (BVI) being two of the Hong Kong. $4.6 world’s most prominent offshore financial centres, the focus of the Formal restructuring has been restructuring and insolvency industries subdued. However, we are aware are almost exclusively cross border. that the majority of refinancing and The main focus is hedge funds, rescheduling of debt agreements for holding companies, private equity and entities registered in the jurisdictions structured finance vehicles in major are currently being undertaken outside capital markets. the scope of formal processes. Real GDP Total unemployment growth/(decline) growth/(decline) There is limited domestic insolvency Restructuring demand builds As global markets continue to open GDP YoY 2009 2009 activity, albeit there have been a number of notable failures in the tourism and hospitality sector over the course of the last year. The continued up, we expect to see a corresponding increase in restructuring and particularly as moratoriums on (6.3%) 53.3% GDP YoY 2020 2020 border closures and absence of enforcement proceedings, state- tourists have led to ongoing strains on revenues in retail, leisure and backed credit schemes and furlough schemes are withdrawn over the (8.2%) No data available hospitality. While local resident coming months. GDP YoY 2021 2021 3.3% business has been able to sustain No data some income in these sectors, albeit We are already starting to see an available on a limited capacity basis, if there increasing number of enquiries from is no opening of borders and return markets such as Hong Kong and 2022 of substantial tourist numbers in Mainland China, especially in relation No data the near future, we anticipate that to management of Chinese property available there will be a significant increase in and credit. Given the substantial domestic insolvency. volume of maturities in property debt falling due there in Q3 2021 and the popularity of Cayman and BVI in corporate structuring for Chinese companies, we expect that market to CPI Average be a potential source of activity for the lending rate foreseeable future. 2020 2020 1.0% 4.5% 2021 2021 1.3% 4.6% 2022 2022 2.3% 4.5% PwC Local contact Simon Conway T: +1 345 938 8685 E: simon.r.conway@pwc.com 25 Global Restructuring Trends – November 2021
In addition, global monetary policies Legislative opening British Virgin Islands have helped to spur considerable From a legislative perspective, Cayman inflows of investment into Cayman is awaiting the implementation of and BVI offshore-based private equity amendments to its Companies Act, funds and special purpose acquisition which will see the inclusion of a companies (SPACs). Some of the more formal restructuring regime for the 2020 Real speculative investments that have first time, outside the format of a GDP (USD bn) been made by those vehicles could be liquidation. Such legislation will see the $1.0 derailed by a higher cost of capital, in appointment of a restructuring officer, the event of interest rate increases. In in conjunction with a moratorium, and this regard, we note that the tightening is expected to broaden the range of of US policy (and to a lesser extent tools available in the jurisdiction’s that of other OECD economies) could rescue regime. It is understood that lead to a substantial increase in formal such legislation will be enacted by the restructuring and insolvency over the end of 2021. coming 12–18 months. Real GDP Total unemployment growth/(decline) growth/(decline) GDP YoY 2009 2009 Cayman Islands British Virgin Islands 4.0% No data available Government support as a % of 2020 Real GDP Vaccination Status ofprogress COVID-19as vaccinations: at 20 of October* GDP YoY 2020 2020 (12.6%) No data available GDP YoY 2021 2021 No data available 51% 2.5% No data available 7% 2022 No data available Share of total population fully vaccinated against Fully vaccinated COVID-19 Partly vaccinated No. of insolvencies – No data available Share of total population only partly vaccinated against COVID-19 British Virgin Islands CPI Average British Virgin Islands lending rate Government support as a % of 2020 Real GDP Vaccination Status ofprogress COVID-19as vaccinations: at 20 of October* 2020 2020 1.8% No data available 2021 2021 No data available 51% 1.7% No data available 7% 2022 2022 Share of total population fully vaccinated against 1.6% No data available Fully vaccinated COVID-19 Partly vaccinated No. of insolvencies – No data available Share of total population only partly vaccinated against COVID-19 *Country data may have been provided on a different date. PwC Local contact Alexander Lower T: +1 284 494 4100 E: alexander.lower@pwc.com Data sources are available on page 85 26
China Many companies are looking at While some larger companies were able restructuring options, diversifying to source sufficient finance to survive, their businesses and stepping up the many SMEs faced severe challenges. pace of digital transformation. Meanwhile, sectors including retail 2020 Real and real estate have seen multiple GDP (USD bn) Following record GDP growth in Q1 2021, restructuring and insolvency cases. The $11,650.4 the momentum was checked in Q2 by real estate sector in particular has been a slowdown in factory activity, higher hit by the “three-red-lines” policies and raw material costs, and new COVID-19 slowing sales, which have restricted their outbreaks in some regions. Nonetheless, ability to refinance. New government the economy looks to be on track to meet regulation of the education sector in July the annual growth target of at least 6%. may also bring potential restructuring Potential headwinds that could derail and insolvency. growth include new variants and further Real GDP Total unemployment supply chain disruption. Accelerating transformation growth/(decline) growth/(decline) With cash positions tight, many As part of the Government support to companies have accelerated digital GDP YoY 2009 2009 9.4% 13.5% relieve the burden of the pandemic, transformation and sought new routes the Administration of Taxation has to market. For example, many fitness targeted incentives at the most impacted and education businesses moved their industries and small businesses. While classes online and developed digital GDP YoY 2020 2020 most of these incentives have now been wound up, a few have been extended to the end of 2021. This includes VAT apps for support. We see these trends continuing as more companies adopt the double-channel strategy to provide 2.3% No data available GDP YoY 2021 2021 waivers for individual business and small- services online and offline, despite the scale taxpayers, income tax exemption for public health workers, and deductions on COVID-19 donation expenses. gradual recovery from pandemic. Simplifying proceedings 7.8% No data available 2022 The government continues to optimise No data Cash positions under pressure the business environment for bankruptcy. available Suspension of business operations at the As of May 2021, there are 14 courts and start of 2020 hit many businesses hard, nearly 100 trial courts for liquidation and especially within transport, entertainment bankruptcy nationwide. The national and manufacturing. These pressures enterprise bankruptcy information were reflected in a soaring number of disclosure platform provided by the insolvencies in manufacturing in H1 Supreme Court has made the trial CPI Average 2020, although cases are expected to process more open and credible to the lending rate fall in 2021 as growth and confidence public. Jurisdictional courts are also moves upwards. helping to make bankruptcy trials simpler 2020 2020 to adopt. Meanwhile, we saw many mega cases in the market. 2.5% 4.0% 2021 2021 1.0% 4.0% China Government support as a % of 2020 Real GDP Vaccination Status ofprogress COVID-19as at 20 of October* vaccinations: 2022 2022 2.2% 4.0% 8% 5% 71% Share of total population fully vaccinated against Fully vaccinated COVID-19 Partly vaccinated No. of insolvencies – No data available Share of total population only partly vaccinated against COVID-19 *Country data may have been provided on a different date. PwC Local contact Victor YK Jong T: +852 2289 5010 E: victor.yk.jong@hk.pwc.com 27 Global Restructuring Trends – November 2021
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