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HMRC have released Spotlight 57: 'Disguised remuneration: tax avoidance by selling future business revenues to a revenue service trust'. 

HMRC describe the arrangements as follows: 

HMRC believe these Disguised remuneration arrangements do not work, will challenge promoters and investigate the tax affairs of those using such arrangements. 

Useful guides on this topic

General Anti-Abuse Rule (GAAR)
What is the GAAR? What taxes does it cover? When might it apply? What tests are considered?  

Disguised Remuneration Zone
What is disguised remuneration? What is the loan charge? How can I settle disguised remuneration, EBT or contractor loans with HMRC?

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Spotlight 57: 'Disguised remuneration: tax avoidance by selling future business revenues to a revenue service trust'