Costs – Protective costs order. The Upper Tribunal (Tax and Chancery Chamber) (the UT) held that it had jurisdiction to make a Protective Costs Order (PCO) and that the governing principles set out in R (Corner House Research) v Secretary of State for Trade and Industry ([2005] 4 All ER 1) would apply accordingly. However, in the present case, the UT set aside a previously imposed PCO on the basis that the order had been made without giving reasons and, more fundamentally, on a misunderstanding of the Revenue and Customs Commissioners' position.