One man service company and share transfer

 I have a successful one man band IT company client.  The sole director would have been even more profitable last year if he had not had to spend so much time on administration.  He has therefore persuaded his partner to resign from her employment and work for him.

He would like to pay her a small bonus of, say, £6,000, and recompense her for the balance in dividends.  He is therefore considering transferring half his shares with a nominal value of £500 to her (he is the sole shareholder).

I am concerned the settlements legislation will mean that all the dividends would be taxed on him.  I am, of course, thinking of the Arctic Systems case here.  The only solution seems to me that she should pay half the value of the company.  If the current year net profits are £100,000, I assume that the value of the transferred shares would be in the region of £50,000 which not only could she not afford to pay, but would involve a CGT liability on him. 

If we authorised and issued a different class of share, say, "A" shares to her, would this get round the above problem, or would it involve other problems?

Is there any way round?

With thanks