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  • If it were possible, other than by issuing different share classes, IR35 would be an irrelevance.

    Contractors could band together as a Ltd, and arbitrarily take any amount of dividends in place of salary, irrespective of contribution.

    From that, you can infer that you can't do it, or everyone would be doing it already.

  • You definitely can have different share classes giving different rights to dividends.

    I don’t know enough about IR35 to know whether that would be a way around it (or if the commercials of a different share class arrangement would mean few people typically want to do it).

  • I meant to say than by issuing different share classes, and was admittedly focused on the Ltd contractor aspect, where HMRC can even then be circumspect of schemes that issue alphabets of share types whereby salary is disguised as dividend.

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