Personally I don't think so, there's little to gain and much to lose. It's cost alot of money already, they lost It'll Cost alot more to appeal The company is in liquidation and has no money to give hmrc if they did win an appeal A precident CANNOT be set for the future by hmrc winning an appeal as all ebt's are different (this one I'm going on what more enlightened ppl say) Edit the growing public opinion is of disgust at what hmrc have put RFC through, MPs calling for inquiries into leaked evidence coincided with the ongoing epetition. I don't see any reason at all, what do they have to gain? Having looked at the reasoning, I'd be bamboozled if they do appeal They have until jan 15th to appeal under a point of law only, not because they're spitting feathers at the verdict