HMRC v Part 26A: Can You Cram the Crown?
Companies, Lenders, and Advisors Must Exercise Caution When Trying to Impose Cram Down on HRMC
August 14, 2023DownloadsDownload Article
This article was first published on the Tax Journal website on July 26, 2023 and in its print issue on July 28, 2023. The entire publication is available at: https://www.taxjournal.com/articles/hmrc-v-part-26a-can-you-cram-the-crown-
Recently, a number of companies have tried to “cram down” HMRC using Restructuring Plans (“RPs”), and HMRC have challenged certain RPs where they consider the proposed treatment of their debts to be unfair. This article presents a background to the relatively new Part 26A RP and examines recent case law and valuable takeaways on cases which sought to compromise HMRC debt.
Republished with the permission of Tax Journal.
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