Barrie, thanks for your contribution. I don’t think that it would be wise to say that a tax scheme works (particularly in the context of a public discussion forum) without detailed discussion of the various pieces of relevant statutory rules and the case law. Any view on a scheme will almost always necessarily be qualified. Hence I am afraid that I cannot give you a simple answer on this. The other aspect to this is of course that so much depends on correctly structuring, documenting and implementing a scheme. However it is legitimate to ask why, as we are nearing the fourth anniversary of the introduction of section 75A, there appears as yet to be no test case seeking to apply the section to the schemes despite what appears to me to be fairly widespread reliance on such schemes.