Caselaw Digest
Caselaw Digest

A Company v HMRC

[2024] EWHC 1611 (Ch)
A company facing a massive tax bill asked a court to stop the taxman from closing it down, saying a sale was imminent. The judge gave them 14 days to complete the sale but made them pay the taxman's legal costs because they waited until the last minute to present their case.

Key Facts

  • Applicant company seeks injunction to restrain HMRC from presenting a winding-up petition for an undisputed debt of over £1.5 million.
  • Applicant claims imminent business sale will allow full debt repayment.
  • Applicant's cashflow insolvency is undisputed.
  • HMRC had previously granted two 'Time to Pay Agreements', both defaulted.
  • Applicant's proposed sale to 'Compass' is uncertain, with no binding offer.
  • Applicant had also explored a share sale to 'Boundary', which was abandoned.
  • Applicant employs 130 employees and 10 apprentices.

Legal Principles

The court has a broad discretion to restrain presentation of a winding-up petition if adverse to creditors' interests.

Insolvency Rule 7.24; Travelodge Hotels Ltd v Prime Aesthetics Ltd [2020] EWHC 1217 (Ch)

A winding-up petition may be considered abusive if not acting in the interests of creditors as a whole, or if its success disadvantages creditors.

Re Maud, Maud v Aabar Block [2015] EWHC 1626 (Ch)

The court has unfettered discretion to adjourn, grant, or dismiss a winding-up petition.

Re Minrealm Limited [2007] EWHC 3078 (Ch)

Outcomes

14-day injunction granted, restraining HMRC from presenting a winding-up petition.

To allow applicant a final opportunity to finalize the sale to Compass; avoids prejudice to HMRC if sale is successful; balances interests of creditors.

Applicant ordered to pay respondent's costs.

Applicant sought considerable court indulgence, presenting crucial evidence late; considering the limited success and applicant's insolvency.

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