Part 26a restructuring: High Court confirms no special status for HMRC

The High Court has sanctioned the Part 26A restructuring plan of Waldorf Production UK PLC (Waldorf) despite significant opposition from HMRC.

A central feature of the decision in Re Waldorf Production UK plc [2026] EWHC 1014 (Ch) is the Court’s firm rejection of the argument that HMRC enjoys a special constitutional status that prevents it from being ‘crammed down’.

Although HMRC’s public function as a tax authority warrants careful judicial scrutiny, it does not give HMRC a veto over restructurings. To hold otherwise would significantly undermine the rescue culture and purpose of Part 26A.

Part 26A restructuring plans