Singapore
What happened in this case was that while the breathing space protection was extended by six months to July by the Singapore court, global mining giant Glencore commenced proceedings against the company through a London arbitration.
Rajah & Tann Singapore's new managing partner Patrick Ang too said that the High Court of England and Wales' recognition of Singapore's new moratorium law is a significant development for Singapore's debt restructuring and insolvency regime. Mr Chua said the recognition by the UK court"brings UK and Singapore courts' insolvency and restructuring regimes much closer together". This is especially important given that more Singapore companies have international businesses.
In a May 2017 feature article in Butterworths Journal of International Banking and Financial Law, legal experts Paul Apáthy and Emmanuel Chua noted that the super-charged moratorium law with its powerful tools of the Chapter 11 process"still retains much of the relative flexibility, speed and cost efficiency of the scheme of arrangement procedure", making it a popular mechanic for cross-border restructurings.
Source: News Formal (newsformal.com)
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