United Kingdom restructuring plan part 26across class cram downhmrc as plan creditor

Re Waldorf Production UK Plc

[2026] EWHC 1014 (Ch)

JurisdictionUnited Kingdom

CourtHigh Court of Justice, Business and Property Courts, Chancery Division (Companies)

Year2026

StatusPersuasive authority

Key Principle

A Part 26A restructuring plan may be sanctioned and the cross-class cram-down power exercised against HMRC, which enjoys no special immunity from being crammed down; the 'no worse off' test in section 901G(3) Companies Act 2006 is construed narrowly by reference to the value of the existing rights being compromised, not broader matters such as the future use of tax losses.

Area of Law

General

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Waterside Class Limited v Mowi ASA & Ors [2026] CAT 32

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