The UK Preventive Restructuring Framework after Brexit: Acknowledging EU’s Supremacy?

This article assesses the degree of cross-fertilisation between the English and European preventive restructuring frameworks, by looking at the innovations introduced in the respective restructuring frameworks since the enactment of the preventive restructuring directive (‘PRD 2019’). The purposes of the article are to highlight the peculiarities of the English approach; discuss their significance for facilitating corporate restructuring in the UK; and finally assessing the likelihood of London remaining one of the leading restructuring centres in the world after Brexit.