Waldorf Production UK Plc [2026] EWHC 1014: HMRC Has No Veto Over Restructuring Plans — Six CFO Action Points on Part 26A, Tax Losses and Cross-Class Cram-Down
The High Court has confirmed that HMRC cannot veto a restructuring plan under Part 26A of the Companies Act 2006. Waldorf Production UK Plc rewrites the rules on tax loss monetisation, HMRC engagement, and the no-worse-off test in distressed M&A.










