Re: Yes, but
So when a person creates two companies, one in the Caymans and one in the UK, and the Caymans company (with one employee - a part time janitor) lends the UK branch £50m at 20% APR, makes profits in the UK of £40m a year for two years and pays the Caymans branch £80m which leaves 0 to pay in the UK because there was no actual profit, and that person is then paid £30m by the Caymans branch, that is EXACTLY the same as me using an ISA that was designed to pay interest with no tax?
OK then...