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The whole thing is a bit like tax avoidance it seems to me. There are myriad ways to get out of it and it's impossible to predict/implement countermeasures for all of them. The only way you can ensure you get what you intend is by putting an honest person in charge who complies willingly... and, well, it's Boris, so you know
This worries me ...
http://waitingfortax.com/2019/09/15/the-flaw-in-the-benn-act/