<p>Tax law has a near impossible task in trying to keep abreast of commercial developments and in no area is this more true than in the tax treatment of financial instruments. The market for financial instruments to manage interest rate risk has grown dramatically over the last 20 years and now accounts for a world-wide market whose value runs into trillions of dollars. London is one of the three major financial centres where these products are developed and actively traded. While a valiant attempt has been made in the UK to try to accommodate these transactions within existing tax law, it has now been recognised that that is doomed to failure.</p>