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"Seems that the SRA & SDT both acted pretty callously and are profligate with their members cash - £46k costs, they are taking the proverbial especially if it was an 'open and shut' case as claimed."

Yesterday, Bailii reported the Court of Appeal's judgment in a case called The Brain Disorders Research Limited Partnership v The Commissioner for HMRC. It was a one day hearing to appeal a UT decision regarding the tax implications of a complex set of relationships between companies, and the creation of an entity designed to allow HNW individuals to obtain tax relief. I will be honest, and state that having skim-read the judgment, I do not proclaim to understand the detail of what this appeal was about.

However, from reading the judgment, it becomes apparent that this was a matter of some considerable complexity, involving a great deal of evidence and a lot of law.

HMRC were the respondents. They prevailed. They were represented by a silk and a junior. They were awarded their costs of the appeal. The level of those costs? £21,915.