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

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.

Tax & Accounting

Barclays Services Corporation v HMRC [2026] UKUT 211: HMRC Wins on VAT Grouping — Six CFO Actions If You Have a Cross-Border VAT Group

The Upper Tribunal has dismissed Barclays Services Corporation’s appeal against HMRC’s refusal to allow a US Delaware entity into the Barclays UK VAT group. Fixed establishment requires real substance on the application date — not backdated arrangements, not substance-in-progress. HMRC’s protection of the revenue powers are broader than previously understood. Six CFO actions for any business with cross-border VAT group arrangements.

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