By Jamie Smyth in Dublin

Ray Grehan, one of Ireland?s biggest property developers, has been declared bankrupt in the UK. He has debts of 312m euros owed to Ireland?s National Asset Management Agency, the bad bank set up to purge Irish lenders of their toxic property loans.

Mr Grehan is the third Irish property developer to apply for bankruptcy in Britain, which has a much less onerous legal regime than Ireland, where bankrupts can wait up to 12 years before they are discharged from bankruptcy.

Details published on the UK Insolvency Service?s website show he was declared bankrupt on December 30 in London. He is listed with a last known address at Bateman?s Row, London, and of lately residing in Maynooth, Co Kildare.

Mr Grehan recently appointed agents to sell his one-bedroom London flat at One Hyde Park, the Candy brothers? development in Knightsbridge, for ?6m.

Under UK bankruptcy law, people are generally discharged in a year and bankrupts can keep their private pensions. Under the Irish bankruptcy regime, private pension pots can be used to pay off creditors.

Irish bankruptcy experts say there is growing interest in ?bankruptcy tourism? after the crisis that led Dublin to accept an ?67.5bn bail-out from the European Union and International Monetary Fund in 2010.

To apply for bankruptcy people must establish that their main centre of interest is in the UK by living there for at least four months. Companies have set up operations in Ireland to provide advice to people seeking to declare bankruptcy in the UK, including IrishBankruptcyUK.

? The Financial Times Limited 2012