Lee A. Sheppard has published U.K. Goes After Deferred Subscription Arrangements, 107 Tax Notes 15 (2005), also available on the Tax Analysts web site as Doc 2005-6603, 2005 TNT 64-9.  Here is part of the Introduction:

The U.K. government is going after many structures that have bedeviled tax administrations across the world for a decade, since Americans gave the green light to hybrid entities and bankers got more creative with hybrid securities, again with American permission. The British are trying to do something about cross-border arbitrage while the Americans are still arguing about whether it is a problem at all. Apparently the year-old tax shelter disclosure rules have worked, because the Finance Bill would go after many specific transactions that the government found out about through disclosure.