You're assuming the law allows it...

just because it gets done, and they can find a tax advisor/attorney to say there's an arguable case that it's legal, does not make it legal.

Nearly everything about that particular structure screams 'abusive tax arrangement' so I would imagine it can be picked apart fairly easily.

An actor being a financial advisor to a Mauritius Trust? Yeah pull the other one.

The problem is simply that HMRC doesn't have the time/resources to investigate and dismantle every single potentially dodgy scheme, so many get away with it. If you're rich enough for this sort of thing to be worthwhile, you probably won't mind the penalties if HMRC does decide it's unlawful, so the potential upside of getting away with far outweighs the downside.

(Until it gets into the public domain)

Posted By: CWC, Nov 7, 10:55:03