Application to set aside a transfer at an undervalue

AuthorMark Watson-Gandy
Pages315-332
Chapter 22


Application to Set Aside a Transfer at an Undervalue

OBJECTIVE

The court has wide powers on the application of the administrator or the liquidator to rewind transfers of the company’s property which have been undertaken at a time when the company is insolvent for no consideration or for significantly less than the value in money or money’s worth provided by the company.1The court will not make an order if it is satisfied both that the company entered into the transaction in good faith and for the purposes of carrying on its business and, at the time the transaction was entered into, there were reasonable grounds for believing it would benefit the company.2

To be challenged, the transaction at an undervalue must have occurred at a time in the period of 2 years ending with the onset of insolvency.3The onset of insolvency means for these purposes either the presentation of the winding up petition, the filing of the administration notice or application if it concludes with the winding up of the company, or the passing of a resolution for the voluntary winding up of the company.4This period is only deemed to run whilst the company is unable to pay its debts (or if it is rendered unable to pay its debts by the arrangement); this is presumed where the arrangement is with a connected person.5

APPLICATION

Proceedings are commenced by application form (Form IAA).

The application should be returnable to the registrar in the Companies Court or to the district judge in a Chancery District Registry or county court with insolvency jurisdiction.

The respondent should be the other party to the transaction that the liquidator or administrator is seeking to set aside.

1Section 238 of the Insolvency Act 1986.

2Section 238(5) of the Insolvency Act 1986.

3Section 240 of the Insolvency Act 1986.

4Section 129 of the Insolvency Act 1986.

5For the meaning of a connected person, see sections 249 and 425 of the Insolvency Act 1986.

316 Corporate Insolvency Practice

COURT FEES

Where fresh proceedings need to be brought, a court fee of £280 is payable.6If the application can be made as part of exisiting proceedings and the application is on notice to other parties, a court fee of £155 is payable.7Where the application is made by consent or without notice in existing proceedings, a court fee of £50 is payable.8

EVIDENCE

The application should be supported by a witness statement by the liquidator or administrator. This will need to address:

ƒ the liquidator’s name;
ƒ the liquidator’s address;
ƒ the order he seeks;
ƒ the date the company was incorporated;
ƒ the registered office of the company;
ƒ the nominal share capital of the company;
ƒ the issued share capital of the company;
ƒ the objects of the company;
ƒ the date upon which the petition to wind up the company or place it into administration or notice of administration was presented;
ƒ the date upon which the company went into liquidation or administration; ƒ that he was appointed as liquidator or administrator of the company;
ƒ the date upon which he was appointed as liquidator or administrator;
ƒ the date of the transaction subject to challenge;
ƒ the particulars of the transaction subject to challenge;
ƒ the value of the company’s asset transferred under the transaction;
ƒ that the asset was transferred for no consideration or identifying the price it was transferred for and stating that this was significantly less than its value in money or money’s worth;
ƒ whether the respondent is a connected person and, if so, why it is said so; ƒ that the company was insolvent (or is to be presumed to be insolvent) at the time of the transaction or was rendered insolvent by the transaction;
ƒ the company did not enter into the transaction in good faith and for the purposes of carrying on its business and there would have been no reasonable grounds for believing that the transaction would benefit the company.9

6Paragraph 3.5 of Schedule 1 to the Civil Proceedings Fees Order 2008.

7Paragraph 3.12 of Schedule 1 to the Civil Proceedings Fees Order 2008.

8Paragraph 3.11 of Schedule 1 to the Civil Proceedings Fees Order 2008.

9Pre-empting the defence under section 238(5) of the Insolvency Act 1986.

The witness statement should exhibit:

ƒ evidence of his appointment as liquidator or administrator;
ƒ a copy of the petition to wind up the company or place it into administration or notice of administration;
ƒ a copy of the winding up or administration order;
ƒ evidence of the transaction subject to challenge;
ƒ the value of the company’s asset transferred under the transaction and of its date and the consideration (if any) paid;
ƒ evidence that the respondent is a connected person (if applicable);
ƒ evidence tending to show the insolvency of the company at the time of the transaction;
ƒ an independent valuation of the property disposed of.

SERVICE

The application and the evidence in support will need to be filed at court and served on the respondent as soon as practicable after it is filed and in any event, unless it is necessary to apply without notice or on short notice, at least 14 days before the date fixed for the hearing.10

The usual rule is that, subject to any other express provision, the application must be served at least 14 days before the date fixed for the hearing.11However, the court does have power, in cases of urgency, to hear an application immediately with or without notice to the other parties.12

Service may be effected personally13or by post in accordance with the rules on postal service under Part 6 of the CPR.14Service on a person may be effected by service on that person’s solicitor, if they are authorised to accept service on that person’s behalf.15

THE FIRST HEARING

At the first hearing, the registrar or district judge will give directions as to whether points of claim and defence are needed and for the filing of evidence. He may also require the application to be served on other people. He may give directions as to whether witnesses are to attend for cross examination. The first hearing will be unrobed and is likely to be in chambers.

10Rule 12.9(3) of the Insolvency (England and Wales) Rules 2016.

11Rule 12.9(3) of the Insolvency (England and Wales) Rules 2016.

12Rule 12.10(1) of the Insolvency (England and Wales) Rules 2016.

13Rule 1.44 of the Insolvency (England and Wales) Rules 2016.

14Paragraph 1(2) of Schedule 4 to the Insolvency (England and Wales) Rules 2016.

15Rule 1.40 of the Insolvency (England and Wales) Rules 2016.

318 Corporate Insolvency Practice

KEY STATUTORY PROVISIONS

Sections 238, 240, 241 and 435 of the Insolvency Act 1986

238 Transactions at an undervalue (England and Wales)

(1) This section applies in the case of a company where—

(a) the company enters administration, or
(b) the company goes into liquidation;

and ‘the office-holder’ means the administrator or the liquidator, as the case may be.
(2) Where the company has at a relevant time (defined in section 240) entered into a transaction with any person at an undervalue, the office-holder may apply to the court for an order under this section.

(3) Subject as follows, the court shall, on such an application, make such order as it thinks fit for restoring the position to what it would have been if the company had not entered into that transaction.

(4) For the purposes of this section and section 241, a company enters into a transaction with a person at an undervalue if—

(a) the company makes a gift to that person or otherwise enters into a transaction with that person on terms that provide for the company to receive no consideration, or

(b) the company enters into a transaction with that person for a consideration the value of which, in money or money’s worth, is significantly less than the value, in money or money’s worth, of the consideration provided by the company.

(5) The court shall not make an order under this section in...

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