What we know for certain is that it is possible to cram down HMRC using a restructuring plan, but not without good reason. In a battleground which ultimately turns on individual circumstances there are some general lessons we can learn from recent cases which might assist in persuading a court to exercise its discretion to cram down.
We have recently authored this article printed in RECOVERY Magazine Autumn 2023 Edition that discusses the approach companies and HMRC might take to managing HMRC debt and cram down in future cases.