“Potentially under challenge are composite companies, umbrella companies, payment split via salary and dividend and payment split via partner dividend, as in the case of Arctic Systems,” explained Roger Sinclair, legal consultant at Egos Ltd."
"However, buried in the Budget’s finer print, the government says any review will accompany new powers to tackle those who hide employment income by drawing dividends, in order to take advantage of the 19 per cent small business tax.
“Since the Pre-Budget Report, further evidence has emerged that employment income is being disguised as dividends in order to take advantage of the small companies’ tax rate, often encouraged by promoters of mass-marketed managed service company schemes.
All of the above is taken from the same document you posted and this scheme is none of these. Also it's not controlled by the UK government but more on the double taxation treaty. In fact the IR uses a similar scheme themselves so it APPEARS for the moment, they wouldn't close this.
Bring back the tories!!!
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