The scheme involved the acquisition of a second hand life insurance policy which was subsequently surrendered realising a capital loss. This took place in 2001 and, as the Special Commissioner Sir Stephen Oliver points out, much of the legislation referred to in his decision has been substantially changed since 2000/2001. This is another example of how contrived tax schemes are not tolerated. Full details of the decision, which was released this week, can be found on the Tax Tribunals Website