The two situations and structures involved were very, very different. Cameron did not achieve any tax benefit from his investment: had the fund been UK registered his tax liabilities would have been no different. It was a simple investment fund which paid dividends like any other, with those dividends and any realised capital gains being subject to uk tax like any other.<p>The Carr scheme on the other hand, which involved the vehicle making loans to investors to offset their gains and thus reduce tax liability was described by hmrc as being at the very aggressive end of avoidance.<p>Cameron was not avoiding or reducing tax liability, Carr was.