GLOBAL RESTRUCTURING TRENDS - SEPTEMBER 2020 PWC.CO.UKSERVICES/BUSINESS-RESTRUCTURING #ACTNOWTORECOVER
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Global Restructuring Trends September 2020 pwc.co.uk/services/business-restructuring #ActNowToRecover
Contents Restructuring Trends: Ireland 24 Appendix 45 A Global View Italy 25 Trends per Executive Summary 01 country 46 Japan 26 Key Themes 02 Malaysia 27 Act Now to Recover 07 Middle East 28 The Netherlands 29 Themes by countries and regions New Zealand 30 Australia 08 Norway 31 Austria 09 Philippines 32 Belgium 10 Portugal 33 Brazil 11 Russia 34 Canada 12 Singapore 35 Cayman and British Virgin Islands 13 South Africa 36 Central and Eastern Europe 14 South Korea 37 China 15 Spain 38 Denmark 16 Sweden 39 East Africa 17 Switzerland 40 Finland 18 Taiwan 41 France 19 Turkey 42 Germany 20 United Kingdom 43 Greece 21 USA 44 Hong Kong 22 India 23 Global Restructuring Trends | PwC
When facing uncertainty, decisive action counts. In the face of continued uncertainty, the latest global restructuring trends explored in this report underline the vital importance of proactive and decisive action by corporates and restructuring practitioners. Getting on the front foot will not only stabilise – we just don’t know how long it will be before businesses in the short-term, but also help them pre-pandemic levels of output are restored. It is gear up for longer term shifts in technology, therefore vital to take the initiative now – when We explore the customer expectations and international trading facing adversity, decisive action counts. For business arrangements. Conversely, waiting until the lifeline recovery plans to be successful, businesses need to challenges and of government support is withdrawn could be clear about the challenges in their path and how significantly reduce the options available and to steer through them. Some of the challenges are public policy increase business vulnerability. immediately obvious. Others may be harder to responses that foresee and potentially the most critical. This isn’t are shaping The world continues to grapple with the most just about surviving, but also maintaining control of market activity in serious global health emergency for a generation. the business, preparing for the future and ultimately And with lockdown, social distancing and 37 economies thriving in the long-term. restrictions on the movement of goods and people worldwide. has come severe economic upheaval. As we explore in Where Next, a series of papers looking at how COVID-19 is affecting different As governments strive to sustain businesses and industries and how organisations can transform to save jobs, policy measures continue to evolve in meet the challenges, the pandemic is accelerating rapid and often unpredictable ways. In the first change and providing a catalyst for innovation and phases of the novel coronavirus (COVID-19) operational modernisation. Prominent examples pandemic, businesses across the world were mainly range from the shift to digital retail to moves towards focused on stabilising liquidity and tackling cash a more sustainable economy. As part of a deals-led flow erosion. Even as economies reopen, the recovery, the plentiful dry powder ready for trajectories of both infection rates and business investment by private equity is set to play a key role recovery remain uncertain. To date, both insolvency in enabling businesses to keep pace with fast- rates and pressure to restructure have generally changing customer demand and seize the been held in check by government intervention. Yet opportunities ahead. these lifelines are now beginning to be wound up. Few would doubt that we’re entering a make or In order for companies to navigate the complex break period, with businesses facing hard challenges their organisation may face and mantain choices ahead. control, we believe that it’s important to focus on four critical areas: operations (e.g. cost In this, the third edition of PwC’s Restructuring competitiveness), liquidity and cash, financial Trends: A Global View, we explore the business restructuring and stakeholder management challenges and public policy responses that are (customers, employees and suppliers, as well as shaping market activity in 37 economies worldwide. financial stakeholders) and strategic mechanisms The report draws on the expert local insights of our (e.g. consolidation or divestment of non-core restructuring advisers and insolvency practitioners, assets). Like the wheels on a car, each needs to be who outline how governments and businesses have in good working order and closely aligned to move responded to the economic upheaval, how they the vehicle forward. expect the next 12 months to play out and the priorities for restructuring ahead. If you have any queries or would like to discuss any of the issues highlighted in more detail, please What comes through strongly from our analysis as feel free to get in touch with one of our local explored later in our report is that businesses can contacts listed in the report. no longer rely on the cushion of government subsidies or suspension of debt obligations. Neither can they afford to wait for recovery to take its course 1 | Global Restructuring Trends | PwC Data sources are available on page 49
Key themes Government support Restructuring activity Insolvency moves back holds back insolvency is set to pick up in Q4 onto the agenda and restructuring 2020 or Q1 2021 Insolvency activity has been curtailed activity, for now As government support is withdrawn, through much of Q2 2020 and Q3 2020, largely as a result of we expect restructuring activity to As revenues dried up and cash calls government support and restrictions pick up. The immediate priorities will became harder and harder to meet, on legal action. There are a few include repairing the balance sheet government intervention has provided exceptions to this, particularly for and dealing with the debts a vital lifeline for many businesses, territories with debtor in possession accumulated during lockdown. With even ones that had previously been processes. The USA is the most revenues subdued and margins strong and well-resourced. Support obvious one, as Chapter 11 provides tight, there will also be pressure on includes loan guarantees and wage the framework and protection to help businesses to eliminate waste, drive subsidies for workers put on short- with restructuring of operations, and down costs and refocus resources time or furlough (more than 40 million more companies have harnessed it as on growth. workers are on furlough in the 37 a tool to get through the emergency. economies we cover in this report). We have also noted increasing levels We have also seen a similar trend in Governments have also offered tax of non-performing loans in territories Canada where, whilst insolvencies holidays and moratoria on such as Italy, Portugal, Greece and have been decreasing, corporate insolvency action. East Africa which will drive lender led restructuring under Canada’s restructuring activity in the coming debtor-led restructuring statute saw This support held down insolvency a significant increase in the first months, as banks look to dispose of rates during the critical initial months half of 2020. these portfolios or outsource the of the crisis (Q2 2020 rates fell across management of these. many markets compared to Q2 2019). In general, insolvencies are expected It would also appear to have eased to increase in Q4 2020 and into 2021, the pressure to restructure and turn especially for those companies that around troubled businesses, including operate in heavily COVID-19-affected those that were struggling before industries that may take much longer COVID-19. But governments can only to recover (e.g. leisure, travel, afford to foot the bills for so long. hospitality, tourism, accommodation, retail etc), as well as for those that have yet to adapt their operations to the new environment. 2 | Global Restructuring Trends | PwC Data sources are available on page 49
Government support Level of funding as a percentage of 2019 GDP as at August 2020 Canada 14.3% China 4.6% France 5.6% Germany 12.5% Hong Kong 10.0% Italy 4.5% Japan 42.2% Russia 3.4% United Kingdom 4.0% USA 13.9% Percentage of the national workforce on furlough as at July 2020 Canada 15.9% France 32.6% Germany 18.7% Italy 45.2% Japan 6.2% United Kingdom 31.5% USA 0.1% Note: A complete circle would represent 100% Note: No furlough data available for China, Hong Kong and Russia Note: Graphs present the G8 countries plus China and Hong Kong 3 | Global Restructuring Trends | PwC Data sources are available on page 49
-15% to -10% -10% to -5% -5% to 0% 0% to 5% Pressure on GDP underlines the need to adapt 2020 Real GDP YoY now and future-proof the business for the variation (%) shifts ahead International Monetary Fund (IMF) projections anticipate that the Canada Italy contraction in GDP stemming from the COVID-19 pandemic will be more (8.4)% (12.8)% marked than the Global Financial Crisis of 2008-09 in all but a few markets. Unemployment could also be higher, rising significantly towards the end of 2020 as government support schemes are scaled back. China Japan 1.2% (5.8)% The trajectory and duration of economic recovery in 2021 are still uncertain, and are likely to vary by market and sector. Much hinges on both a medical solution to the virus and companies’ ability to adapt to the France Russia new environment. Further drivers of demand and growth include people’s (12.5)% (6.6)% comfort with, and ability to, travel. The key focal points for the coming round of restructuring include Germany United repairing the balance sheet and creating the foundation of a healthy (7.8)% Kingdom medium-to long-term recovery. Crucially, there will be opportunities to make the most of rapidly developing restructuring regimes, which (10.2)% provide new tools to work through the issues created by the crisis. These Hong Kong include new legislation implemented or pending in the UK, Netherlands, (4.8)% USA Singapore, Middle East and the Cayman Islands. (8.0)% In particular, where these regimes are more debtor friendly we expect to see increased levels of activity as more corporates harness these tools to get through the crisis as is the case already in the US and Canada. Note: Map presents the G8 countries plus China and Hong Kong 4 | Global Restructuring Trends | PwC Data sources are available on page 49
Private Markets Dry Powder ($bn) The pandemic looks set to accelerate longer term shifts in the economy. This ranges from the move to digital retail to strengthening sustainability. Corporate restructuring is set to play a key role in helping businesses to boost strategic agility and future- proof their business models by simplifying their structures, clearing away non-core operations and freeing up funds for investment. Undeployed capital in private equity and debt funds is at an all-time high, significantly above the levels available during the Global Financial Crisis, creating a launchpad for a fast acceleration in deals and market recoveries. An increasing number of companies have been able to raise new financing without significantly compromising existing debts, and thereby avoided lengthy restructuring processes. For sources of the data presented in this report, please see page 49 at end of the report.Vestibulum venenatis eget odio quis molestie. 5 | Global Restructuring Trends | PwC Data sources are available on page 49
Insolvency appointments Canada China France Germany Hong Kong Italy Japan Russia United Kingdom USA Note: Q2 2020 figures for Germany, France and Russia not included as data was not available Note: Graphs present the G8 countries plus China and Hong Kong 6 | Global Restructuring Trends | PwC Data sources are available on page 49
Act now to recover What then can you do now? The crunch is coming for We believe that there are three key priorities: troubled companies. Even 1. Determine what shape the business is in those in reasonably good The ‘health check’ should look at both the immediate health now face fundamental state of the business and its longer term prospects. What are the immediate threats? How is the company’s changes ahead. As a creditor, competitive environment changing and how fit is it to keep pace? What are the opportunities and how sponsor or other stakeholder can the business capitalise? Is management on the right track? with a financial interest in a Even with the current uncertainty, there is a great deal that can be determined by getting down to the detail in company, how much longer areas such as customer demands, competition, supply chains and access to investment. This not only can you therefore afford to requires restructuring expertise, but also insights into sector trends and how to respond, both locally wait and see? and globally. 2. Clear the path to recovery What is the path to recovery? What are management The key message coming through from our Where Next teams doing to help accelerate progress? Do they have industry perspectives is the extent to which COVID-19 has the capability to deliver the operational changes or not only created severe strains for many businesses in the transactions required? Depending on the state of the short-term, but also accelerated shifts in what customers business and its prospects, potential support ranges expect and how businesses compete. Drivers of disruption from helping to shore up liquidity to divestitures, debt and change stretch from the onward march of digitisation restructuring and facilitating access to fresh capital. to demands for greater sustainability and social inclusion. For the management and shareholders in the driving seat, the shifts underline the need for plans that don’t just 3. Work through divergent interests assume that everything will get back to where they were Key questions include both when to step in and how. before the pandemic, but actively prepare for the new Sponsors may have different priorities from creditors. environment. Wait too long and it may be too late. Management may be wary or resistant to intervention. Yet what does this all mean for you as one of the Different creditor groups may have different rights and stakeholders that aren’t in the driving seat, but still have a leverage. Yet, by establishing a close relationship when significant interest in the health and prospects of the the business is still viable rather than facing insolvency, business? Rightly, you have offered space and support as parties have the opportunity to work effectively businesses have sought to stabilise and stay afloat. But together to secure a better deal. with furlough and other government lifelines being withdrawn, the need to determine whether the business is viable now and equipped for the changes ahead is becoming ever more pressing. You might argue that the trajectory of recovery is too uncertain to know whether the business has a future and what steps are needed to optimise its prospects. But if you do nothing, you might find that the only option is the last resort of insolvency and a consequential loss of value. Acting decisively now could not only avert this, but also ensure that the business is in the best shape to survive and thrive. 7 | Global Restructuring Trends | PwC Data sources are available on page 49
Australia $1,393 12.3% 24.7% 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 1.9% (4.5)% 4.0% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 5.6% Unemployment | 2009 7.6% Unemployment | 2020 8.9% Unemployment | 2021 Australia is facing its first recession in nearly 30 years restructuring and insolvency activity to pick-up in as a result of COVID-19. However, insolvency activity 2021 as the bulk of government support is scaled back. has remained at historic lows. This reflects unprecedented Clearly some sectors are likely to face ongoing challenges, levels of support for business from both the public and especially those where demand is driven by people coming private sectors. from abroad such as the travel and tourism, tertiary education, as well as accommodation and hospitality. A combination of economic stimulus, the temporary suspension of company directors’ obligations to avoid Restructuring will focus on stabilising balance sheets, trading whilst insolvent, a moratorium on winding-up while accelerating digital transformation and reallocation petitions and a strategic withdrawal from enforcement of resources to fast recovery and growth areas. action by tax authorities has allowed many otherwise ‘challenged businesses’ to avoid insolvency. PwC Local contact: Stephen Longley Restructuring activity has also remained subdued. stephen.longley@pwc.com Many listed companies affected by the pandemic moved quickly to raise fresh equity in March and April. Lenders +61 3 8603 3203 have also provided significant accommodation to distressed companies in the form of covenant waivers and principle and interest deferrals. We expect Insolvency appointments Note: Q2 2020 excludes June insolvency data 8 | Global Restructuring Trends | PwC Data sources are available on page 49
Austria $446 12.6% 36.8% 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 (3.8)% (7.0)% 4.5% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 5.3% Unemployment | 2009 5.5% Unemployment | 2020 5.0% Unemployment | 2021 In 2020, Austria’s GDP is expected to decline more sharply Despite the extension of government labour subsidies until than during the Global Financial Crisis. While the current March 2021, we expect that the level of restructuring and recession looks set to be short-lived, GDP is unlikely insolvency activity will increase in the remainder of 2020 to return to its pre-pandemic level by the end of 2021. and into the first half of 2021. It is clear that companies that were already facing financial difficulties at the beginning of Corporate insolvencies fell significantly in the first half 2020, along with those in fast-changing sectors such as of 2020, largely due to government subsidies (liquidity retail, travel and tourism and manufacturing, are likely to improvement actions, government-backed loans and face challenging market conditions. short-time working). The fall also stems from new insolvency legislation, which eliminates the over This underlines the importance of restructuring businesses indebtedness-test until the end of Q3 2020. for long-term viability as well as near-term survival. The main focus for businesses has been on crisis management, securing liquidity and cost reductions. PwC Local contact: Manfred Kvasnicka The economic challenges have led to a rise in unemployment. A number of initiatives to limit the manfred.kvasnicka@pwc.com impact including short-time working have been +43 1 501 88 29 37 introduced. We anticipate that the likelihood of an economic recovery in 2021 will reduce the overall impact on the employment market. Insolvency appointments 9 | Global Restructuring Trends | PwC Data sources are available on page 49
Belgium $530 14.5% 22.5% 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 (2.0)% (6.9)% 4.6% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 7.9% Unemployment | 2009 7.3% Unemployment | 2020 6.8% Unemployment | 2021 In 2020, the Belgian economy is expected to experience The insolvency moratorium introduced during the first the largest annual decline in GDP since the Second World wave of the COVID-19 lockdown has held back War. A return to 2019 GDP levels is expected to take insolvencies. However, we expect the number of several years. insolvencies to increase. There have already been initial signs of this in the last few months. It is worth noting that To date, the largest element of the increase in activity is primarily focused on businesses that were unemployment has been among temporary and contract already facing financial distress entering 2020, with a workers. Companies have drawn on furlough schemes in number of retail companies being especially impacted. an effort to conserve liquidity. As these support measures are phased out, a significant increase in overall unemployment is expected until 2022. PwC Local contact: Thomas Deryckere It is clear that the focus is now on cost reduction thomas.deryckere@pwc.com initiatives, having at the outset of the pandemic been upon conserving liquidity. +32 474 78 04 59 Insolvency appointments 10 | Global Restructuring Trends | PwC Data sources are available on page 49
Brazil $1,840 11.8% N/A 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 0.1% (9.1)% 3.6% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 9.7% Unemployment | 2009 14.7% Unemployment | 2020 13.5% Unemployment | 2021 Restructuring activity was limited in the first months to increase. Companies are also keen to put forward of the pandemic. This is largely due to a combination viable business plans to support financial restructuring. of government subsidies and greater flexibility in the application of labour laws in areas such as reductions Pressure is coming from subdued consumer demand and in working hours. rising unemployment. The temporary suspension of labour regulations that has helped to protect jobs and prevent The rapid moves by private banks to introduce covenant corporate failures also looks set to be phased out. In turn, waivers and grace periods of between two-six months the government’s scope for further economic support may for the payment of principal obligations contributed to the be curtailed by the pressure on public finances. low levels of restructuring. With the end of these support measures, we expect an increase in default rates. As a result, banks have been raising their provisions PwC Local contact: Christine Savignon for bad debt and increasing restrictions on new credit. christine.savignon@pwc.com Estimates suggest that around 500,000 businesses +55 11 3674 2710 had ceased to operate by June 2020, mainly small and micro-enterprises. As we move into the second phase of the economic emergency, we expect restructuring activity Insolvency appointments Note: No data available 11 | Global Restructuring Trends | PwC Data sources are available on page 49
Canada $1,736 14.3% 15.9% 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 (2.9)% (8.4)% 4.9% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 8.4% Unemployment | 2009 7.5% Unemployment | 2020 7.2% Unemployment | 2021 Corporate insolvency dipped significantly in Q2 2020. A their normal operations, as well as whether further number of government wage subsidies, tax deferral and waves of COVID-19-related shutdowns will be ordered. loan programmes have given companies time to review their position and consider their options. However, some We anticipate that restructuring and insolvency activity of these programmes are expiring or are due to be will increase through the autumn of 2020, particularly modified. In the main, lenders have provided support as companies adjust to the new normal and the impact to troubled debtors. of COVID-19 is more fully realised. However, Canada has not yet seen the wave of defaults that were widely Corporate restructuring under Canada’s debtor-led anticipated, though lenders are preparing for many new restructuring statute saw a significant increase in the first troubled debtors in the coming quarter. half of 2020, with as many new cases in Q2 (38 filings) as in all of 2019. Many of these companies were already The overhang of the recession and underlying structural facing financial issues that were exacerbated by the impact changes in the economy will result in a slow return to of lockdown, notably in the retail sector. The economic pre-pandemic levels of economic activity across several impact of COVID-19 in Canada has been particularly industries, including retail, travel and tourism, and profound in the oil and gas, manufacturing, retail trade manufacturing. and construction sectors. The dip in economic activity was compounded by a sharp drop in oil and gas prices. PwC Local contact: Greg Prince It is clear that economic recovery will depend heavily gregory.n.prince@pwc.com on how quickly companies and consumers resume +1 416 814 5752 Insolvency appointments 12 | Global Restructuring Trends | PwC Data sources are available on page 49
Cayman and British Virgin Islands $5 13.2% 7.1% 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 (7.0)% (11.4)% 2.0% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 6.0% Unemployment | 2009 11.6% Unemployment | 2020 5.3% Unemployment | 2021 The economies of the Cayman and British Virgin Islands liquidation process, whilst being afforded the benefits (BVI) are dominated by tourism and hospitality and financial of a moratorium. We anticipate that this will increase services. Tourism and hospitality have been severely restructurings substantially. In BVI, the Court has recently affected by COVID-19-related travel restrictions. However, appointed its first ever ‘light touch’ provisional liquidator, financial services (mainly fund and corporate activity) has similarly opening the door for substantially more financial been buoyed by the stimulus packages put in place by restructuring processes in future. governments worldwide. Insolvencies have generally been subdued, though we’re PwC Local contact: Simon Conway now seeing a steadily increasing flow of enquiries. We anticipate a rise in fund redemptions and an increase in simon.r.conway@pwc.com distressed insolvent scenarios into 2021, as national +1 345 914 8688 governments start to withdraw economic support. Restructuring activity is increasing as a number of major corporate entities seek to restructure their debts and avoid insolvency. This trend is likely to continue into 2021. Legislation is currently pending in the Cayman Islands, which will allow debtors to appoint a restructuring officer, outside of a Insolvency appointments Note: No data available 13 | Global Restructuring Trends | PwC Data sources are available on page 49
Central and Eastern Europe (CEE) $2,262 5.4% N/A 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 (3.0)% (5.0)% 4.8% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 9.0% Unemployment | 2009 8.9% Unemployment | 2020 7.6% Unemployment | 2021 Insolvency activity has been subdued across the Central Looking ahead, we expect an uptick in restructuring activity and Eastern Europe (CEE) region due to government across the CEE region in Q4 2020, once the institutional measures introduced in response to COVID-19. support is ended. These include a moratorium that has enabled banks to adopt a collaborative approach with debtors. The key industries which remain under pressure in The exception is Romania, which has recorded an the region are automotive, retail, tourism and hospitality. increase in the number of insolvencies. PwC Local contact: Petr Smutny Restructuring activity has also remained generally low across the region for the same reasons, though petr.smutny@pwc.com the Czech Republic has seen an increasing trend. +420 251 151 215 Businesses have mainly focused on preserving liquidity by drawing on the government support structures, as well as cost reduction and stabilisation of supply chains. Insolvency appointments Note: No data available 14 | Global Restructuring Trends | PwC Data sources are available on page 49
China $14,343 4.6% N/A 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 9.4% 1.2% 9.2% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 4.3% Unemployment | 2009 4.3% Unemployment | 2020 3.8% Unemployment | 2021 China has seen a significant deceleration in growth Signs are that the government might not prevent the in the wake of the COVID-19 pandemic. downturn of some companies. This will lead to an increase in insolvency activity and put pressure on businesses to Consumer spending fell by 1.38 trillion yuan (US$199.3bn) accelerate restructuring. in the first two months of the year due to the severe impact of the outbreak on restaurants, hotels, tourism, Industries such as financial services, public health and entertainment and transportation sectors. In turn, the care sector are more likely to attract foreign direct passenger car sales saw the biggest drop in nearly investment due to relief policies introduced recently. two decades. PwC Local contact: Victor Jong Chinese regulators have introduced a series of measures to ease the financial pressures on enterprises emanating from victor.yk.jong@cn.pwc.com the pandemic. Financial policies are geared towards certain industries such as medical and life supplies for pandemic +852 2289 5010 prevention, aviation, agricultural and green energy vehicles. There is also tax relief to help ease cash flow or liquidity issues. However, despite this support, the number of insolvencies is still higher than the comparable last year. Insolvency appointments 15 | Global Restructuring Trends | PwC Data sources are available on page 49
Denmark $348 5.8% 9.2% 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 (4.9)% (6.5)% 6.0% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 6.4% Unemployment | 2009 6.5% Unemployment | 2020 6.0% Unemployment | 2021 The number of insolvencies dipped in the first half of 2020 The economic outlook in Denmark is uncertain. The Danish despite the biggest quarterly drop in GDP in Q2 since the National Bank anticipates that recovery to pre-pandemic Global Financial Crisis. levels of output could take several years. As Denmark is a small and open exporting economy, it’s dependent on the This is largely explained by government-funded relief global economy. We expect exporting companies and initiatives such as postponement of VAT payments, salary businesses with foreign operations to be especially compensation to furloughed employees and funding to affected by the current uncertainties. We also see an cover pandemic-related losses. We also saw an expansion unusually high number of vacant leases in the retail sector, of lending and guarantee capacity through state-financed and a low occupancy rate in hotels due to COVID-19. lending entities. During lockdown, Danish courts were only open for self-declaration of bankruptcy, which prevented We expect the support required in the near future will be third-parties or creditors from filing. In addition, banks focused on securing financing to sustain operations. We reported an unforeseen decrease in their lending activities, also expect restructuring support to increase, especially due to the relief initiatives from the government. once the COVID-19 government measures are phased out. We have also seen a focus on cash forecasting and In line with global trends, the emphasis for businesses has working capital optimisation, and we believe this trend been on crisis management, accessing liquidity and supply will continue in the near future. chain resilience. The majority of the government funded schemes are ending in Q3. We therefore expect to see an PwC Local contact: Mads Johansson uptick in insolvency activity. mads.johansson@pwc.com +45 39 45 37 77 Insolvency appointments 16 | Global Restructuring Trends | PwC Data sources are available on page 49
East Africa $240 1.3% N/A 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 5.2% 0.8% 5.1% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 6.4% Unemployment | 2009 8.6% Unemployment | 2020 9.0% Unemployment | 2021 The adverse impact of COVID-19 on East African Given the high leverage and widespread financial distress businesses has been severe. The region’s economies have across East African businesses before the pandemic, these limited capacity to absorb the resultant economic shocks, steps defer rather than resolve the problems. and governments have limited ability to offer significant stimulus and support. Conversely, insolvency activity has dipped. This is despite the recent implementation of insolvency-related legal and This impact is reflected in increasing levels of regulatory reforms in a number of regional markets, aimed non-performing loans. While this would normally at making insolvency regimes ‘business rescue’ friendly. have led to a surge in lender-driven insolvencies, central banks are encouraging banks to favour restructuring We expect to see comprehensive restructuring of balance instead. The result has been an unprecedented upsurge sheets as lenders take stock of their position and the in the volume and value of restructured facilities. In Kenya, outlook for clients in the post-pandemic period. for example, 29% of the total banking sector loan book PwC Local contact: George Weru was restructured between March and June 2020. However, this mostly comes in the form of moratoriums george.weru@pwc.com on debt service obligations and extension of tenor rather than a comprehensive restructuring of balance sheets. +254 727 34 15 84 Insolvency appointments Note: No data available 17 | Global Restructuring Trends | PwC Data sources are available on page 49
Finland $269 5.2% 7.4% 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 (8.1)% (6.0)% 3.1% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 8.3% Unemployment | 2009 8.3% Unemployment | 2020 8.4% Unemployment | 2021 Insolvency activity in the first half of 2020 was down In line with global trends, the emphasis for businesses from 12 month before. This is mainly due to government has been on crisis management, accessing liquidity, moves to expand lending and guarantee capacity to supply chain resilience and rent re-negotiations. SMEs, ensuring sufficient access to finance and reducing the structural buffer requirements for the banking sector. We anticipate that, in the event of a renewed COVID-19 Access to capital has been gradually improving over outbreak followed by further lockdowns, there will recent months. be a severe impact on SMEs. This contrasts with larger companies, which are more dependent on The government has also initiated targeted liquidity exports and global demand. improvement actions for the most severely impacted sectors, such as aviation and shipping. PwC Local contact: Michael Hardy As a result of these initiatives, restructuring activity michael.hardy@pwc.com has remained relatively quiet. +358 20 7877442 Insolvency appointments 18 | Global Restructuring Trends | PwC Data sources are available on page 49
France $2,716 5.6% 32.6% 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 (2.9)% (12.5)% 7.3% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 9.1% Unemployment | 2009 10.4% Unemployment | 2020 10.4% Unemployment | 2021 The impact of lockdown on the French economy has Furthermore, these economic difficulties could also spur been compounded by the dent to important sectors the need for refinancing of some of the lending supported such as aerospace, automotive and tourism. Government by the guarantee programme. support to help viable companies to ride out the impact has included loan guarantees to encourage bank lending. The government is currently transposing the 2019 EU restructuring directive into law. This should improve the As a result, restructuring activity has been focused prospects for secured creditors, relative to shareholders on two factors. The first is shoring up the balance sheets and unsecured creditors. Some temporary measures have of otherwise viable companies applying to the guarantee also been implemented to ease the restructuring processes programme. The second is stabilising companies that had during the post-pandemic period. Examples include flexible already faced difficulties before the pandemic, including access to asset deals for existing shareholders, in absence some retail businesses affected by digital competition. of other credible options. Over the next few months, we expect the number of PwC Local contact: Sébastien Dalle companies in financial distress or bankruptcy to increase, resulting from the relative weakness of the economic sebastien.dalle@pwc.com rebound across many sectors. +33 1 56 57 80 13 Insolvency appointments Note: Q2 2020 excludes June insolvency data 19 | Global Restructuring Trends | PwC Data sources are available on page 49
Germany $3,486 12.5% 18.7% 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 (5.7)% (7.8)% 5.4% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 7.7% Unemployment | 2009 3.9% Unemployment | 2020 3.5% Unemployment | 2021 The German economy faced significant headwinds We expect to see an increase in restructuring activity from the outbreak of COVID-19 as a result of its reliance as government support is scaled back. in exports. However, economic activity has begun to slowly get back on track on the back of some €1.3tn The continuing impact of the pandemic is likely to spur in government subsidies. The support includes tax restructuring within the automotive sector in particular. reductions, furloughs and state aid in form of loans Alongside the near-term dent in consumer demand and equity. stemming from the outbreak, carmakers face a longer- term shift towards hybrid and fully electric vehicles. Further relief has come from the temporary suspension of the obligation to file for insolvency until the end of Furthermore, we expect to see increased restructuring September 2020, with an option to extend this until the in challenged sectors such as retail, shipping and end of March 2021. As a result, insolvency proceedings industrial manufacturing. declined by nearly 10% in May 2020 compared to May 2019. Restructuring activity and default rates have also PwC Local contact: Daniel Judenhahn been subdued due to government support. daniel.judenhahn@pwc.com The main focus of businesses in the last months has +49 69 9585 6976 been on accessing liquidity, crisis management and supply chain stabilisation. Insolvency appointments Note: Q2 2020 excludes June insolvency data 20 | Global Restructuring Trends | PwC Data sources are available on page 49
Greece $210 12.8% N/A 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 (4.3)% (10.0)% 5.1% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 9.6% Unemployment | 2009 22.3% Unemployment | 2020 19.0% Unemployment | 2021 The impact of the COVID-19 pandemic has been A new Bankruptcy Code is about to come into effect (from heightened by the importance of tourism to the Greek 2021) incorporating the EU restructuring directive. This will economy (some 20% of GDP). Coordinated monetary, help to streamline bankruptcy processes, bring together fiscal and regulatory support has helped to ease the restructuring regimes under one code and reduce the time difficulties faced by businesses across the economy. to discharge. It will also usher in early warning mechanisms and a truly out of court workout. as well as the digitisation As a result, restructuring activity has been low in 2020 of procedures. We believe that the changes will make so far. The winding down of government and bank restructuring, pre-insolvency procedures and bankruptcy support, paired with the fact that servicers are taking more efficient. over the majority of non-performing loans, will be key drivers of increased restructuring activity over PwC Local contact: Ioannis Theologitis the next period. ioannis.theologitis@pwc.com +30 21 0687 4654 Insolvency appointments Note: No data available 21 | Global Restructuring Trends | PwC Data sources are available on page 49
Hong Kong $366 10.0% N/A 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 (2.5)% (4.8)% 3.9% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 5.2% Unemployment | 2009 4.5% Unemployment | 2020 3.9% Unemployment | 2021 The government has supported business and jobs through We expect the hard-hit travel and aviation sectors to take three rounds of funding totalling HKD288bn (US$37.1bn) longer to return to 2019 activity levels as the catalyst of since the start of 2020. Moreover, in April, the Hong Kong lockdown changes people’s behaviour and priorities in the Monetary Authority instructed all banks to grant a longer term. Accommodating these changes will require a six-month loan repayment holiday to SMEs, which has significant rethink when it comes to liability management. given respite to SMEs across a range of different sectors. With economic strains continuing and new bank financing As a result, insolvency activity has been relatively muted becoming more difficult and pricier to secure, we anticipate this year, with only 62 compulsory winding up orders this that the number of insolvencies may go up in Q4 2020 or year compared with 126 for the comparable period last early next year. Businesses and lenders are unable to hold year. The lower numbers may also be attributable to the out indefinitely despite the government measures. impact of COVID-19 on court operations. PwC Local contact: Peter Greaves Nonetheless, many businesses, especially those in the consumer and retail industries, have faced significant peter.greaves@hk.pwc.com liquidity issues, requiring them to focus on reducing their highest outgoings – typically rental expense and +852 2289 1826 employee wages. Insolvency appointments 22 | Global Restructuring Trends | PwC Data sources are available on page 49
India $2,876 7.0% N/A 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 8.5% (4.5)% 6.0% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 5.6% Unemployment | 2009 11.0% Unemployment | 2020 9.8% Unemployment | 2021 Insolvency rates have been held in check by government adjust loan arrangements in sectors under stress. and regulatory intervention. While unemployment rose initially, it has started to fall as Recent regulatory action includes an increase in the businesses come out of lockdown. Business sentiment is threshold for invoking proceedings, inclusion of a special also encouraging. PwC research has found that more than insolvency resolution framework for SMEs and a 80% of businesses are confident that the economy can moratorium on fresh initiation of proceedings for six return to the pre-pandemic levels by June 2021. The months. The Reserve Bank of India (RBI) has also research underlines the importance of getting on introduced a Resolution Framework for COVID-19 Related the front foot in seeking to restructure businesses and Stress, which aims to revive real estate sector activities and boost viability. Respondents in our survey attribute their mitigate the impact of financial stress on borrowers. resilience in the face of stress and confidence in their ability to rebound to operational flexibility, robust crisis Business agenda is primarily focused on maintaining the management and effective process/product innovation. debt-equity ratio, reviving demand and optimising cost management. In turn, the government has been focusing closely on credit availability, resource utilisation and PwC Local contact: Dinesh Arora entrepreneurship. Further interventions include the RBI dinesh.arora@pwc.com prudential norms, which grant banks a one-off window to +91 98 10 19 12 91 Insolvency appointments Note: No data available for Q2 2020 23 | Global Restructuring Trends | PwC Data sources are available on page 49
Ireland $389 7.1% 18.8% 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 (5.1)% (6.8)% 6.3% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 12.6% Unemployment | 2009 12.1% Unemployment | 2020 7.9% Unemployment | 2021 Restructuring activity in Ireland has remained relatively to the direct impacts of COVID-19 when assessing subdued. The insolvency rate in the first half of 2020 was if a director acted recklessly when trading while insolvent down by around 30% compared to the same period in on the basis they act in good faith and responsibly. 2019. Contributing factors include payment breaks for New temporary insolvency legislation is being introduced. borrowers, together with the impact of government support The most notable changes are to extend the examinership schemes. The acid test of viability for businesses will come period by a further 50 days if required, permit remote/ when the government aid is withdrawn. virtual creditor meetings and an increase the winding up debt threshold to €50,000. A key focus for businesses has been the renegotiation of leases and the granting of forbearance. This has led We expect large multinational businesses to bounce back to some high-profile disputes between landlords and their quickly, but the SME sector will take a number of years to tenants. There have already been a number of liquidations recover. A lot of SMEs are already highly leveraged from in the retail sector, driven primarily by administrations and the last downturn. They will therefore require some form of downsizing of UK-parent companies whose difficulties restructuring, refinancing and/or change of management in were accelerated in the COVID-19 lockdown. order to survive. Schemes such as the recently introduced State Credit Guarantee for 80% of borrowings will be There is likely to be an increase in restructuring and crucial to the survival of these businesses, which are the insolvency activity in the first half of 2021. The Office of the lifeblood of the Irish economy. Director of Corporate Enforcement issued guidance, and some comfort, to directors that they would give due regard PwC Local contact: Declan McDonald declan.mcdonald@pwc.com Insolvency appointments +353 1 792 6092 24 | Global Restructuring Trends | PwC Data sources are available on page 49
Italy $2,001 4.5% 45.2% 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 (5.3)% (12.8)% 6.3% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 7.7% Unemployment | 2009 12.7% Unemployment | 2020 10.5% Unemployment | 2021 Restructuring and insolvency activity was relatively A significant increase in new insolvency and restructuring quiet in the first half of 2020 as a result of emergency is expected in the first quarter of 2021, once the existing legislation and generally supportive approach of banks support measures have ceased. In the case of distressed and creditors. This includes the option to suspend companies, there may be the need for capital restructuring. payments for 6-12 months. In both cases, investors could play a significant role, The gathering recovery of the economy is expected with the Italian banking system involved in a new wave to continue in the coming months. Confidence has of de-risking (through the disposal of non-performing continued to improve in all sectors. loan portfolios and single names, as well as outsourcing of their management to dedicated platform). Recent deal Stronger companies have found it relatively easy activity also suggests that there is likely to be further to access bank finance. Loans are secured by government consolidation among TIER-2 banks. guarantees to cover losses and support short-term cash needs. However, businesses that took advantage of last PwC Local contact: Michele Peduzzi year’s government-backed debt restructuring measures have generally not been able to benefit from the current michele.peduzzi@pwc.com guarantees. As a result, they may need to re-open discussions with banks and look for solutions without +39 02 8064 6371 government support. Insolvency appointments 25 | Global Restructuring Trends | PwC Data sources are available on page 49
Japan $5,082 42.2% 6.2% 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 (5.4)% (5.8)% 2.4% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 5.1% Unemployment | 2009 3.0% Unemployment | 2020 2.3% Unemployment | 2021 While GDP has fallen, the number of insolvencies has Other than COVID-19 related developments, there are not increased, and the rate of unemployment has been likely to be more opportunities for business restructuring. stable. Since the Global Financial Crisis, Japanese These include portfolio reorganisation, operational companies have been improving their level of cash restructuring and divestments in Japanese corporations. and shareholder equity. This is due, in part, to track record of growth in conglomerates, sometimes retaining unprofitable In response to the pandemic, the government and non-core businesses. Furthermore, we expect to see a banks coordinated moves to bolster liquidity and help consolidation of the banking system, as smaller regional corporations to protect their cash positions. Further banks have been affected by a slow economic recovery steps include a government scheme to support SMEs, and poor interest rates. The government appears open to with funding equivalent to more than 20% of 2019 GDP. supporting any regulatory reform required to enable the Some specific sectors (e.g. automotive, auto-parts, consolidation process. hospitality & leisure, retail & consumer) have been PwC Local contact: Kiwamu Sugimoto heavily disrupted by the COVID-19 outbreak and have yet to recover. Consequently, if the COVID-19 outbreak kiwamu.k.sugimoto@pwc.com continues or there is a renewed surge in cases, there is likely to be more restructuring. +81 80 3519 9482 Insolvency appointments 26 | Global Restructuring Trends | PwC Data sources are available on page 49
Malaysia $365 4.2% N/A 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 (1.5)% (1.7)% 9.0% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 3.7% Unemployment | 2009 4.9% Unemployment | 2020 3.4% Unemployment | 2021 To protect jobs and stimulate the economy, the Central PwC Local contact: Victor Saw Bank of Malaysia initiated an automatic moratorium on all loan/financing, payments, principal and interest victor.saw.seng.kee@pwc.com by individuals and SME borrowers for a period of six +60 3 2173 1677 months from 1 April 2020. The moratorium was further extended for three months to those who are directly impacted by the pandemic. Insolvency activity has been subdued due to various initiatives by the government to protect companies against collapse. This has given the businesses disrupted by the pandemic some lifelines. However, we anticipate insolvency activity to pick up in 2021. Especially on highly geared companies when the government pulls the brake on existing support measures Insolvency appointments Note: No data available for Q1 2020 and Q2 2020 27 | Global Restructuring Trends | PwC Data sources are available on page 49
Middle East $2,692 3.1% N/A 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 0.5% (4.5)% 3.7% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 6.9% Unemployment | 2009 10.9% Unemployment | 2020 9.0% Unemployment | 2021 Liquidity has come under pressure following the decline in pandemic demands a more holistic solution for borrowers oil prices and the COVID-19 pandemic. In 2020 there have who have taken advantage of these schemes. already been a number of high profile corporate collapses in the region. Widespread legislative changes in the bankruptcy and restructuring frameworks of most major regional A combination of government support and initiatives jurisdictions could support distressed businesses in have so far helped to delay more widespread defaults. restructurings and also provide alternative options for For example, the UAE Central Bank has issued directives creditors. In 2020, there has already been a number of to offer relief measures to banks, corporates and long running and high profile cases put forward under the individuals within the country and implemented the new Kingdom of Saudi Arabia bankruptcy law where there Targeted Economic Support Scheme (TESS), to support are now over 500 cases in total. Earlier in the year in the banks in providing relief to corporate borrowers. The TESS UAE, the Financial Reorganisation Committee accepted scheme is currently due to expire in Q4. Similar measures the first two applications to support multi-billion dollar have been taken elsewhere in the region, notably by the restructurings of prominent groups in the region. These are Saudi Arabian Monetary Authority. The support provided likely to pave the way for an increased interest in the formal by banks has typically comprised of deferrals rather frameworks now in place to support distressed situations. than waivers. As the deferrals come to an end, we expect the economic PwC Local contact: Mo Farzadi pressure created by lower oil prices and the impact of the mo.farzadi@pwc.com +971 56 682 0649 Insolvency appointments Note: No data available 28 | Global Restructuring Trends | PwC Data sources are available on page 49
The Netherlands $909 4.9% 28.0% 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 (3.7)% (7.7)% 5.0% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 4.4% Unemployment | 2009 6.5% Unemployment | 2020 5.0% Unemployment | 2021 Following sharp falls in GDP and rises in unemployment, The sectors that are likely to face increasing pressure the Dutch economy is not expected to recover to pre-crisis include retail, travel, transportation & logistics, but also levels until 2024 in more conservative scenarios. the construction sector. The construction sector was already under pressure pre-COVID-19, driven by the Nonetheless, insolvency rates have stayed remarkably so-called PFAS-crisis and nitrogen-crisis, during which low, driven by support from the government, as well as a limited number of permits were issued by the government the banking sector. For affected companies, the options for new building projects. include partial payment of a company’s personnel costs by the government, the postponement of tax payments In light of these developments, the new WHOA and government guarantees on newly issued bank loans. restructuring law, which is expected to become At the same time, banks have offered to suspend interest effective during the second half of 2020, is becoming and amortisation payments. As a result, insolvencies were even more relevant. This so-called ‘Dutch scheme’ concentrated in sectors where the impact of the crisis was allows for a court-approved restructuring plan, in most severe, such as travel and leisure. which hold-out positions are less likely to frustrate a (consensual) restructuring. It also allows for a As government support is expected to decrease significantly faster restructuring process. over the coming months and tax liabilities and interest and amortisation payments become due, a wave of insolvencies is expected during Q4. This would be PwC Local contact: Peter Wolterman even more likely if there is a second wave of infections. peter.wolterman@pwc.com +31 088 792 50 80 Insolvency appointments 29 | Global Restructuring Trends | PwC Data sources are available on page 49
New Zealand $207 21.3% 66.3% 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 0.3% (7.2)% 5.9% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 5.8% Unemployment | 2009 9.2% Unemployment | 2020 6.8% Unemployment | 2021 The level of formal insolvencies has remained broadly We anticipate a significant uptick in insolvency and consistent with last year, but the rates have actually restructuring activity in Q1 2021, once the existing support decreased since the outbreak of COVID-19. This is largely measures wind down. The main focus will be businesses due to government initiatives that have provided in sectors such as tourism, hospitality and leisure and businesses with additional liquidity (e.g. wage subsidies, tertiary education, along with primary industry segments cashflow loans and tax regime changes). However, the reliant on recognised seasonal workers. As these banking sector has also played a key role through allowing sectors look to recover, much will depend on the lifting principal holidays, covenant waivers and the extension and of border restrictions. re-purposing of existing loan facilities. More broadly, we expect that many business owners In addition, the temporary relaxation of certain directors’ will take 2020 as a ‘moment of truth’ and run a ruler across duties is intended to give boards of viable businesses the their businesses from top to bottom. Financial, operational confidence to trade on through the COVID-19 uncertainty. and strategic restructuring solutions (e.g. divestment of non-core entities) will be used to create businesses that The introduction of a new Business Debt Hibernation are more internationally competitive, environmentally scheme provides an option for businesses to obtain a sustainable and clear on their value propositions and seven-month standstill on existing trade debts. However, competitive advantages. This will act as a springboard for those under greater financial pressures, this may have for long term viability and growth beyond the recovery. to be used alongside other restructuring processes (e.g. a creditor compromise) to be effective. PwC Local contact: John Fisk john.fisk@pwc.com Insolvency appointments +64 4 462 7486 30 | Global Restructuring Trends | PwC Data sources are available on page 49
Norway $403 4.5% 8.5% 2019 GDP (bn) Funding | August 2020 Furlough | July 2020 (1.7)% (6.3)% 2.9% GDP YoY | 2009 GDP YoY | 2020 GDP YoY | 2021 3.3% Unemployment | 2009 13.0% Unemployment | 2020 7.0% Unemployment | 2021 The economy has been hit by both COVID-19 and In comparison to other markets, Norwegian regulations low oil prices, resulting in the lowest GDP growth in and procedures for debt negotiations have been seen decades. Tourism, travel, entertainment, hospitality and as rigid, and rarely used. This could now change. offshore are amongst the most heavily affected sectors. The new legislation has similarities to Chapter 11 in However, overall insolvency activity has remained stable the US and is expected to improve the scope for as a result of extensive economic support packages from meaningful negotiations and solutions. the government. Many businesses have focused on crisis management, cash flow forecasting and securing liquidity. PwC Local contact: Per Christian Wollebæk We expect restructuring and insolvency activity to increase per.wollebaek@pwc.com in 2021 as government support unwinds. Moreover, a new temporary law, expected to become permanent, may +47 952 60 318 contribute to an increased number of debt negotiations, with the aim to avoid unnecessary bankruptcies. Insolvency appointments 31 | Global Restructuring Trends | PwC Data sources are available on page 49
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