Para 18 shows even more HMRC incompetence re loan charge etc:
Para 20 shows the importance of getting proper tax advice from a regulated firm (otherwise personal bankruptcy looms for monies received 10 years ago under profit extraction schemes that were assured as having only a remote risk of successful attack - harsh).
PSL's Aikido dividend scheme is in para 21.
Para 61 is interesting re quasi-sham/mislabelling arguments re substance (reality) of a transaction.
I'm rather surprised the Respondents' counsel appears to have not distinguished Rangers, but seems to have accepted it applies (unless that concession was due to the APNs per para 27, but they were received later on 5 July 2013 and possibly that time lag could have made a difference here).
Interesting also that if they now go bankrupt with most of their wealth still in the EBT I think that's protected from their trustee in bankruptcy for the usual reasons.