The PFA has obviously argued that the nature of the coaching scheme means that the coaches are a) not likely to fly very often and b) that any money they receive is likely to be very small. Whereas the CAA will has shown the Revenue the scale of charges for flight tests and discussed typical utilisation rates for examiners. The fact you are not typical does not get away from the fact that as a licensed examiner, you are operating in a very different regime to the PFA coach.