Er.....but it is OK really Roger.
In fact it was so OK that HMRC knew about it and were fine about it until, well, they decided they wouldn't be fine about it.
The comforting thing here is that Barrowman has the clout to fight them. Which won't go down well.
The rules are there. If schemes meet the rules then it's hard to have sympathy for HMRC when they start crying about people taking advantage of those rules.