GLOBAL RESTRUCTURING TRENDS - #ACTNOWTORECOVER #ACTNOWTOGROW #VALUECREATION NOVEMBER 2021 - PWC

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GLOBAL RESTRUCTURING TRENDS - #ACTNOWTORECOVER #ACTNOWTOGROW #VALUECREATION NOVEMBER 2021 - PWC
Global
Restructuring
Trends
#ActNowToRecover
#ActNowToGrow
#ValueCreation

November 2021
GLOBAL RESTRUCTURING TRENDS - #ACTNOWTORECOVER #ACTNOWTOGROW #VALUECREATION NOVEMBER 2021 - PWC
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.
GLOBAL RESTRUCTURING TRENDS - #ACTNOWTORECOVER #ACTNOWTOGROW #VALUECREATION NOVEMBER 2021 - PWC
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.
GLOBAL RESTRUCTURING TRENDS - #ACTNOWTORECOVER #ACTNOWTOGROW #VALUECREATION NOVEMBER 2021 - PWC
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
GLOBAL RESTRUCTURING TRENDS - #ACTNOWTORECOVER #ACTNOWTOGROW #VALUECREATION NOVEMBER 2021 - PWC
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
GLOBAL RESTRUCTURING TRENDS - #ACTNOWTORECOVER #ACTNOWTOGROW #VALUECREATION NOVEMBER 2021 - PWC
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
GLOBAL RESTRUCTURING TRENDS - #ACTNOWTORECOVER #ACTNOWTOGROW #VALUECREATION NOVEMBER 2021 - PWC
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
GLOBAL RESTRUCTURING TRENDS - #ACTNOWTORECOVER #ACTNOWTOGROW #VALUECREATION NOVEMBER 2021 - PWC
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
GLOBAL RESTRUCTURING TRENDS - #ACTNOWTORECOVER #ACTNOWTOGROW #VALUECREATION NOVEMBER 2021 - PWC
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
GLOBAL RESTRUCTURING TRENDS - #ACTNOWTORECOVER #ACTNOWTOGROW #VALUECREATION NOVEMBER 2021 - PWC
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
8
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
16
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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