A rare EBT "win" for the taxpayer (well done to the taxpayer's counsel - beating JGQC on a dodgy PB-W RT scheme is no mean feat). (A sort of pyrrhic victory though if you factor in PB-W's 10% fees.)
Looks correct to me. HMRC will be most displeased.
I'm not sure why HMRC don't do a forced DoTAS disclosure, like they did recently here: https://www.bailii.org/uk/cases/UKFTT/TC/2021/TC08235.pdf
Interesting also the mention of the dodgy "fiduciary receipts" switch to potentially avoid the Loan Charge. See: