I felt compelled to blog this article as it pinpoints how in the race to the bottom for profit creative contractual schemes are be put in place to box out an employee’s rights but presumably in a manner that is tax efficient for the employee if they are a high earner as the company becomes the source of income and they are an employed director.
Is it tax avoidance? Certainly in my view. No doubt the Revenue here will be revisiting this issue.
Creative contractual arrangements are often struck down in Court and you cannot just drive coach and fours through the law of agency in an effort to exclude liability in contract,employment or tax law.