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

Swiss Centre Ltd v HMRC [2026] UKUT 227: HMRC Kills a £34 Million Deduction — What Every CFO Must Know About Loan Relationships, Guarantor Payments and Unallowable Purpose

The Upper Tribunal has handed HMRC a comprehensive win in Swiss Centre Ltd v HMRC [2026] UKUT 227, confirming that a £34 million payment taken to P&L was not deductible for corporation tax — not under the loan relationship rules, not as capital enhancement expenditure. Six CFO actions before your next group finance review.

Tax & Accounting

The Distributions Framework Overhaul: HMRC’s 23 June Consultation Could Reshape Demergers, Share Buybacks and Owner-Manager Exits — Six CFO Actions Before 14 September

HMRC’s 23 June 2026 consultation on modernising the distributions framework proposes sweeping changes to capital reduction demergers, share buybacks, loans to participators, and capital vs income treatment for individual shareholders. If these proposals become law, the structuring toolkit for owner-manager exits, PE transactions, and pre-sale demergers will change fundamentally. The consultation closes 14 September 2026.

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