Author name: Mark Hendy

Mark Hendy is an interim and fractional CFO specialising in PE-backed and founder-led businesses, operating through Tanous Limited. A repeat-mandate CFO trusted by many of the UK's leading PE houses.

Tax & Accounting

HMRC’s New Advance Tax Certainty Service Is Live: What the £1 Billion Binding Clearance Regime Means for Every CFO Planning a Major UK Investment

HMRC’s Advance Tax Certainty Service launched on 1 July 2026, offering binding statutory clearance on Corporation Tax, VAT, SDLT, PAYE and CIS for major UK investment projects over £1 billion. Here is what every CFO with large capex in the pipeline needs to know — including the process, the limitations, and seven actions to take now.

Tax & Accounting

HMRC v Align Technology Switzerland GmbH [2026] UKUT 00256 (TCC): When VAT Exemptions Get Reclassified — and What Every CFO Selling Medical or Dental Products Must Do Now

On 7 July 2026, the Upper Tribunal ruled that Invisalign clear aligners are not dental prostheses and are standard-rated for VAT. HMRC v Align Technology Switzerland GmbH [2026] UKUT 00256 (TCC) reverses the FTT’s opposite conclusion and creates immediate obligations for any business that relied on the earlier decision. Here is what every CFO in healthcare, dental, medical devices, or life sciences must do right now.

Tax & Accounting

Trees v HMRC [2026] UKUT 00092 (TCC): When HMRC Oversteps on Director Liability — and What Every CFO Must Know About Personal VAT Penalty Risk

The Upper Tribunal has set aside a £2 million Director’s Liability Notice in Ashley Charles Trees v HMRC [2026] UKUT 00092 (TCC), finding HMRC’s conduct an abuse of process. The case clarifies the limits of personal VAT penalty exposure for directors — and the procedural rights that CFOs must be prepared to assert.

Tax & Accounting

UK Care No. 1 Ltd v HMRC [2026] UKUT 00090 (TCC): The Imported Loss Ruling Every Cross-Border CFO Needs to Understand

The Upper Tribunal’s decision in UK Care No. 1 Ltd v HMRC clarifies when cross-border loan relationship losses are blocked as ‘imported losses’ under s.327 CTA 2009 — and when they are not. With £150 million at stake and PE structures routinely using offshore SPVs, this is a ruling every CFO involved in cross-border debt or migration transactions needs to understand.

Tax & Accounting

HMRC v BlueCrest Capital Management [2026] UKSC 18: The Supreme Court’s Salaried Members Ruling and What Every LLP Must Do Now

The UK Supreme Court unanimously dismissed BlueCrest’s appeal on 1 July 2026, confirming that significant influence under the salaried members rules must derive from the LLP agreement itself — not informal or de facto influence. With a £197 million tax bill at stake, this is the most important LLP tax ruling in a decade. Here is what every CFO and managing partner must do now.

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