Still gathering requirements...
I'm not holding out on hearing from the ex-Sanzar directors, or any of their old staff, to support us. Any old promises are only just that now. Garraways said the reason Sanzar closed down was they had no "product" following the EBT rule changes. The most they are doing is referring us to Cobham Murphy, who are doing the low cost bulk appeals for us just now, probably with a view to some future bigger business with us.
When I asked Cobham Murphy on costs, they said something like the appeal letter is free, but any future fees due will be discussed/agreed in advance. So if HMRC vs Sanzar scheme user X does go to tribunal in future (which it may or may not), then my interpretation is that Cobham will want to be paid (naturally) - and this could be funded by the individual X, or by a group of scheme users since the outcome would affect everybody obviously.
The outcomes I see, in order of preference:
1. HMRC sits on this for months/years, decides the scheme is valid and not worth challenging (E.g. if their appeal against Rangers fails), and retracts the re-assessments.
2. HMRC investigate the scheme, challenges it at tribunal, Cobham Murhpy/other legal folks defend for us, we win the case
3. Ditto but HMRC win, and all the scheme users have to cough up.
or 4. you don't appeal, and cough up anyway to be done with it.
In any case, it's probably going to take ages, so if you have a big potential liability I would start putting money aside now, just in case.