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09 January 2025
The UK real estate sector is poised for significant legal developments in 2025. Ashurst’s specialist real estate disputes lawyers Alison Hardy, Joe Perry-Courtade, and Debbie Eliad unpack the key legal issues, trends, and cases shaping the industry. From the push for net zero to the latest developments in tenant insolvency, this discussion provides insights to help stakeholders navigate an evolving landscape.
Episode talking points include:
•Net Zero Targets: The growing focus on energy-efficient retrofits and sustainability is driving disputes over stranded assets, demolition vs. retrofitting, and service charges for funding upgrades.
• The Building Safety Act: Key rulings like Triathlon Homes are reshaping landlord and developer obligations, with significant appeals expected in 2025.
• Service Charge Disputes: Cases such as Brewster House highlight the tension between landlord obligations and tenant liabilities for structural defects.
• Landlord and Tenant Act 1954 Consultation: Proposed reforms could dramatically alter security of tenure rights in the commercial leasehold market.
• Telecoms Code Challenges: Disputes over old agreements, leases, and renewal rights remain contentious, with key clarifications needed.
• Tenant Insolvency and Restructuring Plans: The Cineworld case showcases how restructuring plans are impacting landlords and tenants, with valuable lessons for proactive negotiation.
List of cases discussed:
•Triathlon Homes LLP -v- Stratford Village Development Partnership and others [2024] UKFTT 26 (PC)
•Adriatic Land 5 Limited -v- The Long Leaseholders at Hippersley Point [2023] UKUT 271 (LC)
•AP Wireless -v- On Tower UK Limited [2024] UKUT 263 (LC)
•Gravesham Borough Council -v- On Tower UK Ltd [2024] UKUT 151 (LC)
•UK Commercial Property Finance Holdings Ltd -v- Cine-UK Ltd & Anor [2024] EWHC 2475 (Ch)
•Responding to the consultation on the Landlord and Tenant Act 1954.
To listen to this and subscribe to future episodes in our enforcement mini-series, search for ‘Ashurst Legal Outlook’ on Apple Podcasts, Spotify or your favourite podcast player. And to find out more about the full range of Ashurst podcasts, visit ashurst.com/podcasts.
The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Listeners should take legal advice before applying it to specific issues or transactions.
Alison:
Hello and welcome to the Ashurst Real Estate Dispute Resolution New Year's Podcast. I'm Alison Hardy, and today we're diving into what we consider will be some of this year's most interesting and topical real estate disputes. Net zero, the Building Safety Act, service charges relating to structural defects, the Law Commission's consultation on the 1954 Act, telecoms, and insolvency. So joining me are two of my team, Joe Perry-Courtade and Debbie Eliad. Welcome to both of you.
Joe:
Thanks Alison. It's great to be here.
Debbie Eliad:
Yes, thank you. I'm looking forward to discussing these important topics with you both.
Alison:
So New year. New year's resolutions, either of you?
Joe:
Yeah, I actually have two, which I've rolled over from last year because I unsuccessfully tried to do them last year. So I've got, playing a lot more tennis, which I have already started doing, so that's good. And to pick up the piano again, which I did when I was much younger, but only got to grade one, so hoping to develop that a bit more this year. How about you, Debbie?
Debbie Eliad:
So I'll be working on my Duolingo streak, hoping to finally get some positive messages from the green bird. So I'm working on French at the moment, so hopefully next year I'll be able to answer in French.
Alison:
Ah yes, the green bird, I've got a very angry green bird. I've been trying to learn Italian on Duolingo, and yeah, I've had a real drop off since I came back from Italy, so I too have that as my year's resolution, Debbie. So yeah, we could go all European this time next year.
Joe:
Right, then should we move on to the first topic? Let's start with one of the most significant challenges facing the real estate industry today, I think, which is the push towards net zero. Alison, can you give us an overview please, of how net zero targets are impacting real estate?
Alison:
Yeah, absolutely. The drive towards net zero is fundamentally reshaping the real estate landscape, but for a long time it was a long way off into the distance, and it's now started to come much more front and centre, notwithstanding that the white paper, which was going to set out 2027 and 2030 deadlines hasn't then been brought into legislation. But what's happened is banks have started to make that a requirement and investors are much more aware of it. And so it's almost as if that legislation's there. And so this is now becoming a real and present risk for commercial property owners and investors.
The risk of those assets becoming stranded if they can't keep up with those standards. And it's a particular problem for older buildings and buildings which just can't be upgraded. It's creating a dual pressure on property investors. Those assets which are potentially stranded are starting to see their asset values fall. And at the same time, those very same assets need substantial capital investment in order to improve their energy efficiency.
Joe:
Yeah, definitely. I can see how that's a really big challenge. And how are you seeing this crop up in the courts as well?
Alison:
There's been a couple of things, I think it's worth exploring. The first is much more well known. So some property owners are coming to the conclusion that it's just not financially viable for them to retrofit their buildings to bring them up to standard, and are instead just looking to demolish them and start again. So one well-published, one we all know about is the Marks & Spencer's decision to knock down rebuild its Oxford Street store. Now that received a lot of criticism from environmental groups, and then ultimately Michael Gove, who was then the Secretary of State, he turned down M&S' planning application. And in rejecting that application, Gove said that there was a strong presumption in favour of repurposing and reusing buildings, which of course music to the environmental campaigners' ears. But the high court held that the Secretary of State had misinterpreted the national planning policy framework when he made that decision. And that was one of the reasons for which the court quashed Gove's decision.
Joe:
Yeah. Now following the recent change of government, M&S' plans have actually been given approval by Angela Rayner, so we're seeing planning application challenges on the retrofit and rebuild debate.
Alison:
Yeah, I think we are going to see much more of that. And there was another one of these, so M&S isn't alone in this one. There was another one called One Museum Street in London, where a community coalition called Save Museum Street, crowd funded an application for permission to judicially review Camden Council's decision to grant planning permission for the substantial demolition and redevelopment of buildings on Museum Street. And again, one of their key concerns was that the developer should be retrofitting rather than demolishing the existing buildings. In that case, the court refused to grant planning... grant permission, sorry, to judicially review. So permission for planning had been granted. The judicial review is turned down, but I do think it's quite easy to see that we'll have more of those types of challenges. There's definitely much more local community action, and particularly around environmental issues.
Joe:
Definitely. And beyond planning application challenges then, what are the key developments in this area that landlords and tenants should be looking out for in 2025?
Debbie Eliad:
Well, there are many ways We could see net zero related disputes crop up in 2025, and we could probably have our own podcast series on that, but one area I would highlight is service charge disputes. It's been interesting to see what listed real estate companies have included in their annual report about achieving net zero. One company stated that it anticipates a cost of approximately £100 million in bringing its portfolio up to EPCB by 2030. And that it expects to recover two thirds of those costs from tenants through service charge payments. The extent to which landlords can recover such costs from their tenants will be dependent upon each drafting, but I anticipate you will see challenges from tenants who feel that they're bearing the brunt of these costs.
Alison:
Yeah, can really see that coming front and centre. And moving on to another critical area, let's discuss the Building Safety Act. A bit of a viper's nest, this, with all of the lots of legislation and amending legislation and regulations that have been brought in. Debbie, can you explain to us what the key developments have been in the last year?
Debbie Eliad:
Yes. So there have been a number of developments in this area, but the one that I'll focus on happened at the beginning of the year. So this was the first tier tribunal handing down its decision in Triathlon Homes and Stratford Village. This was the first case to consider a contested application for a remediation contribution order.
Alison:
Yeah, so the Act's introduced two different enforcement routes. We've got remediation orders and remediation contribution orders. What's the difference?
Debbie Eliad:
So remediation orders require a landlord to remedy certain building safety defects such as fire safety defects within a specified time. They can only be granted in respect to buildings that contain at least two dwellings and are over 11 metres high or have at least five stories. A remediation order is made against the relevant landlord. So this would be the landlord who has an obligation to repair or maintain the building. This could be a management company, a freeholder, or a superior landlord. On the other hand, remediation contribution orders require a specific company or partnership to make payments in connection with the remediation of relevant defects, so that those costs aren't passed all onto the lease holders via the service charge. This could be the current landlord, the developer, or a person associated with those parties. It's essentially a mechanism which allows landlords who forward funded remedial works to seek contributions from others, including the original developers of the building.
Alison:
Thanks, Debbie. That's really helpful to understand those two. So going back to Triathlon Homes, why is that case important?
Debbie Eliad:
So the decision clarified a number of points that were not clear on the face of the Act, and shows that the Tribunal is committed to implementing the policy behind the Act, which is to shift the financial burden of remediation onto the original developer.
Alison:
And what did the Tribunal clarify?
Debbie Eliad:
The Tribunal confirmed that remediation contribution orders are effectively non-fault based. The Tribunal granted an order against the developer and its parent company, despite the fact that the developer's parent company had changed since the completion of the development.
Alison:
So a company that wasn't involved in the original development, was on the hook?
Debbie Eliad:
Yes, that's right. It's a surprising outcome, and no doubt parties investing in real estate companies will be upping their inquiries and seeking contractual warranties in respect to liabilities for completed developments. And we could potentially see breach of warranty claims in this area in the future.
Alison:
Yeah, you can definitely see much more DD on deals and certainly potential claims there. Definitely want to watch. And what else came out of that Triathlon Homes decision?
Debbie Eliad:
The tribunal made clear that remediation contribution orders can be made in respect of costs that were incurred prior to the Building Safety Act coming into force. Also, the respondents had sought to argue that remediation contribution orders could not cover costs aimed at minimising risk whilst waiting for the remediation works, such as waking watches and the installation of temporary fire alarms. The tribunal confirmed that remediation contribution orders could cover those costs, and the government has subsequently amended the legislation to make that clearer.
Joe:
Yeah, and just to flag that the triathlon decision has been appealed as well, so we'll be looking out for the Court of Appeals Judgement in 2025 this year as well. And we're also expecting the appeal in the Hippersley Point case. That case concerned the operation of Paragraph 9, Schedule 8 of the Act, which provides that no service charge is payable by tenants for legal or professional services relating to relevant defects. In the Hippersley case, the upper tribunal held that this provision is not retrospective, if the tenants had not paid the service charge by the time the provision came into force in June, 2022, they're then no longer payable to pay the charges.
Debbie Eliad:
Well, that seems a bit unfair to the lease holders who paid up before June, 2022. I expect we're likely to see more tribunal cases focused on the interpretation of the Building Safety Act in this coming year. So on the topic of service charges, particularly in relation to structural defects, Joe, why do you think we're going to see more activity in this area?
Joe:
So I think the introduction of the Building Safety Act has made more leaseholders reflect on what costs they should be required to pay, but the Act does have a limited effect. It only applies to certain high-rise buildings and specific types of defects like you were describing earlier, Debbie. And in some cases such as the Brewster House case, tenants may be out of time to call on the protection of the Building Safety Act, because it only applies to works completed within the period of 30 years back from June, 2022. Where the act doesn't apply, we could see tenants bringing more creative arguments to justify why they shouldn't have to shoulder certain spending.
Debbie Eliad:
Interesting. And so what happened in the Brewster House case?
Joe:
Sure. So to quickly give you the background, the case involved two blocks which have been constructed using something called the large panel system. And that involves bolting together concrete slabs to form the walls and floors of the building. The structural integrity of these sorts of buildings came into question after something called the Ronan Point disaster in 1968, where gas explosion caused a collapse. And so since the 1960s, Tower Hamlets had carried out reinforcement works on the buildings, but review in 2018 actually found that further works were required. And that then led to Tower Hamlets spending around £8 million on structural works and allocating a significant portion of those costs down to Leaseholders.
Debbie Eliad:
I'm sure the leaseholders weren't happy about that. So what arguments did they put forward?
Joe:
Yeah, I can't imagine they were happy about that. So their principal argument was that the leases didn't permit the landlord to charge for the structural works under the service charge because the works didn't fall under the landlord's obligations to maintain or repair the buildings. Those terms, so maintain and repair typically involve remedying deterioration or damage rather than in this situation addressing inherent structural defects.
Debbie Eliad:
I see. And did the upper tribunal find [inaudible 00:12:44] in their favour?
Joe:
Yes, they did. So the tribunal found the obligation to maintain and to keeping good of substantial repairing condition, didn't include remedying structural defects that were not due to deterioration or damage. They said that the term maintain should be interpreted to mean preserving the building's functional condition rather than improving it or making it safe from inherent defects. The tribunal also concluded that a sweeper clause, which required the landlord to do all necessary works for the proper management, maintenance, et cetera, of the building. Didn't extend to such extensive structural works either. That type of clause was intended to cover unforeseen items but not obligations vastly different in kind and scale from those specified in the lease.
Debbie Eliad:
Sounds like a great outcome for the tenants, less so for the landlords. So what should landlord and tenants be mindful of, moving forward?
Joe:
Yeah, it's a good case to demonstrate that landlords and tenants should be looking out for specific things here. So I think landlords need to make sure that their service charge provisions are clear, and that any changes to the apportionment method are justified and communicated properly to the tenants. And then tenants on the other hand, I think should check what charges they're asked to pay and challenge any that seem unreasonable or unfair. And both parties, of course should seek legal advice to engage in those disputes effectively if they arise.
Alison:
I often think about that, Bruce, the house case, when I walk my dog past it, as it's just up the road from where I live. You know you've become a real property geek when you're even thinking about cladding remediation when you're walking the dog.
Joe:
Definitely.
Alison:
But we're often asked, aren't we about inherent defects, and it goes well beyond residential service charges. I think this is a really good example about a concept that's come out of a residential service charge matter, but applies also in the commercial world. This question of are inherent defects, part of the repairing obligation, it comes into dilapidation planes in the commercial sector as well. So these kind of issues that get determined by a tribunal in one area might well come through into another area in the future. So staying on the topic of landlord and tenant, many of our listeners will be aware that the Law Commission recently published a consultation paper and survey on the operation of the Landlord and Tenant Act in 1954. The last review of this was of course back in the early 2000s, which I remember really well, and it was linked to the introduction of the civil procedure rules following the Woolf Reforms. Now here we are more than 20 years later and there's another consultation on whether the Act is fit for purpose. So Debbie, what does the consultation paper say?
Debbie Eliad:
In short, the law commission is taking a big picture approach and tackling the fundamental question of whether the current system which gives tenants security of tenure by default is actually appropriate for the modern commercial leasehold market. They've outlined and are consulting on four different models of how security of tenure could operate. So the first is no security of tenure, meaning that tenants would have no automatic right to renew their tenancy. The second is a contracting in model, which would mean that tenants would only have a right to renew if they contracted in. The third is contracting out model, which is what we currently have. This provides tenant with security of tenure by default, but landlords and tenants can agree to opt out of it. And finally, mandatory security of tenure, meaning that all business tenancies would automatically have security of tenure, and there's no option to opt out.
Alison:
So lots of different options, and of course we do also sometimes see contractual renewal rights included in leases as well as having the '54 Act [inaudible 00:16:24] instead. So it sounds like we might have some pretty drastic changes ahead.
Debbie Eliad:
Potentially yes, but potentially not. The law commission recognises that any change to the current system could have a really big impact on the commercial leasehold market. And they've acknowledged that if there are problems within the current system, it might be better to fix those, rather than introduce a completely new system. The commission intends to conduct an extensive consultation so that it has a very strong evidence base on which to come to its conclusions when it makes those recommendations to the government.
Alison:
Okay, so what's happening next?
Debbie Eliad:
So stakeholders will be invited to respond to the questions in the consultation paper, and also to the commission survey, which is aimed at gathering market intelligence on the current operation of the act. Both the consultation and the survey are open for responses until the 19th of February this year. The commission will then review the responses, come to a conclusion about which model of tenure it wants to recommend. And once it's reached that conclusion, it's expected to produce a second technical consultation paper, which will deal with the detail of how the recommended model would actually work in practise. At the moment, there aren't any timings until when we see that second consultation paper published.
Alison:
Okay. So this current consultation then another consultation, but no draught bill anytime soon. Though I guess actually thinking about it, that 2003 change to the '54 Act was brought about by a regulatory reform order. So once they decide what they're doing, they could bring it in relatively quickly. On the other hand, if there's a bill, then it could be quite some time before we see any real change, and it might or might not have a significant impact, depending on what they decide to do.
So I definitely encourage anyone who deals with the '54 Act to think about responding to that consultation. I think it's important that the recommendations the law commission put forward are firmly grounded in the experience of those of us who deal with it day in, day out. It's painful often to think about responding to these consultations, and it's easy to think somebody else will have more things to say or better things to say. But I think often if we don't respond, we end up with legislation which we somewhat regret. So certainly I'm going to be trying to make myself respond by the 19th of Feb, and it'd be good if others could too.
Joe:
Yeah, I think that's right, Alison. Although I think this might be a controversial opinion, but I do think there's not really an imminent need to change the '54 Act. I quite like how it fits together. I don't see many issues with it cropping up day to day in the cases that I'm working on, but I do wonder if the law commission might have been best concentrating on other areas that need attention. It could just be me.
Alison:
No, I agree. I was a bit annoyed that they decided to go for the '54 Act, because it feels to me that the AGA saga in the 1995 Act is more of a day-to-day problem in the commercial real estate world.
Joe:
Yeah.
Debbie Eliad:
Yes, I think there are plenty of other options and other piece of legislation they could have looked at. Another piece of legislation which also is a big topic of conversation, is the electronic communications code. Since that came to force in December, 2017, we've seen a steady stream of case law on it, and this year has been no different. So Joe, do you think that's likely to continue?
Joe:
Yeah, I think so, Debbie, there are still quite a few unanswered questions. We're still dealing with a range of telecoms matters last year, as you know, and whilst case law has helped clarify some areas, there's still lots of clarification needed. One point that I think it would be useful to get some guidance on is what amounts to a reasonable period when you're looking at complying with a notice to remove apparatus under paragraph 40 of the code. There's so many different types of telecoms apparatus, ranging from small cables to tonnes and tonnes of storage equipment sitting in data centres. And of course the latter will take much longer to remove than the former. So is there a risk that a site provider's removal notice could be invalid if they don't give a long enough period for removal in the notice itself?
Debbie Eliad:
Yes, you're right, that's a good example of the continued necessity that remains around the operation of the code, although unfortunately we can't guarantee that we will receive any guidance on that in 2025. Thinking about the past year, are there any cases that stood out to you?
Joe:
Yeah, it's quite difficult to choose actually. As we're still in a period where a significant proportion of telecoms agreements were entered into prior to the entry into force of the new code, I think our focus on two cases concerning old agreements. So the first of those cases was AP Wireless V. On Tower UK. And this case was all about whether two old code agreements were leases or licences.
Debbie Eliad:
That sounds a bit like a legal techie point to me. So what's the significance for landowners?
Joe:
Yeah, so the distinction has important implications actually for the rights of the parties, particularly for renewal and termination. So if the agreements were held to be leases, then the operators' renewal rights would be limited to the 1955 regime that we were discussing earlier. Whereas if the agreements were licences, then the operator could make an application for renewal and the code. Now 1955 agreements can be terminated on shorter notice, the site provider has more grounds on which to terminate, and currently any rent payable under a renewed agreement would likely be higher, because the no scheme valuation approach doesn't apply.
Debbie Eliad:
Interesting. And so what was the outcome?
Joe:
So in the case, the judge found that was both agreements granted exclusive possession, which indicated that both them would be leases. One of the agreements was granted for a minimum term, and that's not a sufficient term certain to qualify as a lease. So one of the agreements was a lease and the other was a licence.
Debbie Eliad:
Okay, so that sounds like a good case to keep in mind when you're dealing with old agreements. What was the other case you wanted to raise?
Joe:
Yeah, so this case again involved On Tower UK who were clearly busy in the courts last year, and that was the case opposite Gravesham Borough Council. And in that case there was a rooftop telecom site, and it involved the renewal of rights under the 1954 Act and the telecoms code again. The operator was an occupation under a 1954 Act protected tenancy, and they sought a renewal. Now, the site provider served notice under the 1954 Act and they wanted to terminate the agreement on the basis that they needed to carry out some roof works. The operator filed a claim for a new tenancy with the court under the '54 Act regime, but then they failed to serve the proceedings on the landlord in time. And so to kind of cover up that eventuality, they then brought a renewal application under the code as well.
Debbie Eliad:
I see. And why is that case significant?
Joe:
Well, as you might expect, the upper tribunal held, the operator had actually exhausted its rights under the 1954 regime, and so was prevented from making a further application under the code. Otherwise the operator would've had two attempts to renew, or as the judge put it, they would've had two bites at the cherry. I think it's a welcome decision for site provider as it helps provide some certainty. Operators get the one chance to renew, and that's it.
Debbie Eliad:
Thanks, Joe. Yes, I agree, that's quite good to have that certainty. I think we'll see more cases in this area in the coming year.
Joe:
Yeah, I think that's right, Debbie. So finally turning to a perennial hot topic then, with real estate insolvency. The latest UK government company insolvency statistics, which were released in mid-December 2024, showed that the number of insolvencies in 2024 were lower than in 2023, but that said the past two years have seen corporate insolvency levels at the highest level since the global financial crisis in 2008, 2009. When you look at the chart on the insolvency services website, there are two peaks, one around the global financial crisis, and then again in 2023 with this year just behind. 80% of the company insolvencies in November were creditors voluntary liquidations. So there's been an increase in administrations, and the lowest proportion of the total figure of CVA's, which are historically low. How have we seen this play out this year for landlords then Alison?
Alison:
Yes, insolvency. Rarely a podcast goes by without me talking about it. We're certainly seeing plenty of it in lots of different forms too, aren't we?
Joe:
Mm-hmm.
Alison:
It's been talked about, I think in grand terms, ever since the COVID pandemic, with lots of warnings of a tsunami of insolvencies heading towards us. But in reality, what we've seen is lots of banks entering into standstill agreements with their borrowers, or refinancing, giving time for things to settle down. And that tsunami really hasn't materialised. We are seeing more than just a trickle though.
And the stats that you've just mentioned showing insolvency is lower this year than last year, are delayed, they don't predict the future. So it's a good picture of what's happened, but not what's about to happen.
That said, that low proportion of CVA's, I think probably is a trend. I think it's linked to the continuing use of restructuring plans. So CVAs were all the rage in the pandemic, but restructuring plans, they're very much the new kid on the block, and much more expensive actually to carry out than a CVA. They've really started to become fashionable, and I think that's because of that cross-class cram down, which is always a nightmare to say, and we're seeing more of them being deployed by insolvency practitioners. So a key case for landlords in that space was Cineworld, and that restructuring plan was sanctioned in September.
Joe:
Oh, yeah. And the restructuring plans proposed by the Cineworld companies was quite controversial, weren't they?
Alison:
Certainly with the landlords, yes. Now what they did was enforce rent reductions or lease terminations on landlords for a large number of the cinema state. And the plans were particularly controversial with two of the landlords. And the reason for that is because before the restructuring plan was put in place, those two landlords had obtained promises from Cineworld that in return for the landlords writing off rent arrears and reducing ongoing rent, Cineworld wouldn't seek to compromise those rents further if they put forward a restructuring plan in the future. But they did.
Joe:
Right, okay. So why were the plans sanctioned then?
Alison:
So the properties were over-rented, and without restructuring, the UK business would be continually financially dependent on its US arm to keep going, and the US arm wasn't willing to prop up the UK business indefinitely. So whilst landlords voted against the restructuring plans of Cineworld on the basis of those promises, at the sanction hearing, Cineworld argued that yeah, they were breaking their promises, but the dissenting landlords would be no worse off than they would be in the event of the quote, "Relevant alternative," that's a test that's deployed in these restructuring plans. And the relevant alternative was the administration of those tenant companies. And on that basis, the court sided with Cineworld.
Joe:
Right, okay. So what practical steps can landlords take then when faced with an unfavourable restructuring plan?
Alison:
I think this is one of the reasons why they are so popular, because landlords were doing quite well at challenging CVAs, but challenging restructuring plans is increasingly difficult. Landlords are often in a class called the out-of-the-money creditors, and they have very little influence on the process, certainly where there's debt to be refinanced, for example. Interestingly though there were a couple of landlords who were winners in the Cineworld case. They had reached agreements with Cineworld to have their leases completely excluded from the restructuring plan altogether. And I think negotiating for exclusion from the plan is probably the best outcome, but you can't always achieve it. I think it depends on your leverage with them and how valuable your particular location is.
Debbie Eliad:
That's a really interesting case. It seems to highlight how being proactive can really pay off. As we often talk to landlords about how to handle tenant insolvency, including how to spot the warning signs early and steps that they can take to help prevent or reduce the impact on their property interest. The Cineworld case sounds like one that we will definitely have to bear in mind in those discussions.
Alison:
Yeah, I think so. It's the old Boy Scout be prepared thing, isn't it?
Joe:
Mm-hmm
Alison:
Being prepared on insolvency always pays off. Thank you both for spending time with me today. It's clearly going to be another really interesting year ahead for real estate dispute.
Joe:
Yeah, definitely. I think the range of topics and points we've discussed today just show that it's an evolving landscape, and staying on top of all of these developments is just really important.
Debbie Eliad:
Yes, I agree. It's been a pleasure chatting with both of you and I look forward to seeing what happens in the next year, and we can check if any of our predictions are correct.
Alison:
Yeah, absolutely. And maybe in French and Italian, hey, Debbie? Thank you to our listeners as well for choosing this podcast. If you have any questions or need further information, please do reach out to any of our team here at Ashurst. Until next time, goodbye and happy a new year.
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