They were presented with a tax bill which they disputed, perfectly within their right to do so. The disputed tax bill was found in favour of the PLC at the FTT, HMRC appealed to the UTT, that appeal was thrown out in favour of the PLC. The PLC don't have to fight those decisions, that only applies to the losers in both decisions, that happens to be HMRC. I have to say though, as a UK taxpayer i'm very perturbed that HMRC are pursuing a case which has went against them twice to a very substantial cost to the British public. As i'm sure you are yourself.