Except where the fiduciary and the assistant were acting in a joint venture, the accessory is not liable for profit made by the fiduciary: they are only liable for any profit that they made. In Ultraframe at [1600] (followed in Aerostar) Lewison J stated, ‘I can see that it makes sense for a dishonest assistant to be jointly and severally liable for any loss which the beneficiary suffers as a result of a breach of trust. I can also see it makes sense for a dishonest assistant to be liable to disgorge any profit which he has made as a result of the breach. However, I cannot take the next step to the conclusion that the dishonest assistant is also liable to pay to the beneficiary an amount equal to a profit which he did not make and which has produced no corresponding loss to the beneficiary.’