Accountancy Age has reported that Dave Hartnett, HM Revenue & Customs' acting chairman has said that HMRC is encountering new and aggressive avoidance techniques. He said there are:
pockets of advisers who were designing bespoke, niche avoidance schemes to business, and that a pattern was emerging where companies would move brands into an offshore company and then pay for the use of the brand in order to skirt tax.
It's something we have been saying for some time (see page 51 here). I sincerely hope it will be cracked down upon. It is a blatant abuse of the concept of tax compliance.