I have never believed that HMRC just got it "so wrong", a sort of "honest" mistake as a particularly odious character might say.
I've always believed there was a concerted attempt to destroy, or at least severely wound us, and all for who's benefit?
Why did HMRC wait until 2010 to land on us an inflated bill, when EBTs appeared in accounts from 2001. Why the penal interest and penalties, the argument of us blatantly abusing the system doesn't add up, given two tax tribunals judged we had largely been correct in our administration of EBTs.
If you take HMRC's purpose as to collect tax, they have had an epic fail and heads should roll over this. They declined offer of over £10m from Murray plus probably lost opportunity for payment plan of remaining £10m. Then lost further £20m from Whyte. Then lower tax take from lower wages 2012-2017.
Above is probably about £60m of collectable revenue if HMRC had played their cards differently Makes you wonder, well me anyway, of their motive!