Hare brained tax scheme

Usual limited company husband and wife setup, however with a twist.

The wife lives with the child in their home in Brunei, and acts as company administrator, etc. She's very well qualified having an accountancy background (albeit not-UK) and holds an MBA. All courtesy of the apparently very generous Brunei government.

The wife left the UK to bring the children up in Brunei last year and has completed a P85 and got the necessary "NT" Tax code for the work which she currently does for the company. All perfectly standard and above board as far as it goes.

Where it gets a bit tricky is that the husband (interim HR director) has worked up a scheme whereby he thinks that paying himself only enough to cover the overheads of a small flat in East London, food and beer, he can legitimately pay the entire remainder of the companies funds to his wife as salary suffering only PAYE, Employees NI and Employers NI on his small scale earnings (probably about 15k per year).

As all of the companies earnings will be paid out in tax deductable salaries, there would be no corporation tax to pay as the overall P&L would be effectively zero.

Husband sole director, holding a 51/49 shareholding with wife who is just an employee (Office Administrator).

My first temptation was to say "B*gg*r off", but IR35 and moral implications aside, I'm struggling to quote HMRC chapter and verse why they can't do this.