See para 280 et seq. Looks like the right decision to me.
https://www.bailii.org/ew/cases/EWHC/Ch/2022/784.html
So tax avoidance does pay.
Interesting how BDO repeatedly described their tax advice as "robust" and yet the courts have effectively said that tax advisers cannot be robust about complex tax advice without a risk of a client negligence claim (if they're wrong) and must now give a tax risk warning in such cases to avoid that (which in turn is unhelpful for the client vis-à-vis HMRC in cases like this)! See:
https://www.accountingweb.co.uk/any-answers/looks-like-a-resounding-win-...