When HMRC closes a loophole they can't apply the changes retrospectively so if a controlled and operated scheme rather than an individual's scheme is already then there's a chance it can still go through but who's to say what's been diddled with the HMRC declaration and where they're actually putting the money? I know first hand that they closed down a few of the Cyprus based loan dealies from April gone so I'm assuming the only ones left will be in Jersey/Isle of Man type places and they are not easy = not cheap or more exotic/less regulated places which obviously offer a different set of problems.
I've heard from a sneaky prawn for those looking for something simple, UK based and transparent, that prop firms' (or at least one at any rate) advisers generally favour a LLP type structure with an individual/corporate partner split which should be fairly attractive given the new sub 20% Tory CT rates for under 300k but again this can cause a different set of issues. I didn't get to prod enough to figure out how (if at all) the bookies were dealing as I didn't want to be too obtrusive yadda yadda with said issues (mainly corporate classifications and issues re main rate tax) but with 10% at risk it's more than a bit of an issue IMO.
Good luck anyhow and I'd be very interested to hear what they come back to you with if you don't mind sharing... by confidential email of course.