Readers' forum: Arctic circle

I have a client who is about to take on a consultancy project with a success fee that might run into millions of pounds receivable (if at all) over the next two years. If he sets up a company to receive it the 38.1% dividend rate negates any benefit of lower corporation tax rates and the 32.5% rate only provides a marginal saving. But if he could give half the company to his wife they could each withdraw a substantial dividend each year as a kind of pension and benefit from her basic rate band. Is that considered possible?

I recall when Garnett v Jones was going through the courts there were arguments about whether it was better for the husband to subscribe for all the shares and make an outright gift of half of them or for the wife to subscribe for her shares with...