Mr A owns 100% of C Ltd. 90% of 'his' shares are held on trust for Mr B. (There's an informal bit of paper with an agreement that Mr B will get the 90% on sale of C).
The main purpose of this was so that A could get all the reserves in dividends (so divi waiving not an option) but B retain any proceeds on sale.
The question has been rasied by the bank - shouldn't B be taxed on 90% of the divs? Is there a way around this?