[HarryT]

If there is a "loophole" in the law, then the law needs to be changed, but I really don't think that you can blame anyone for minimising their tax bill by entirely legal methods. I strongly suspect that you don't voluntarily pay more tax than you're required to, do you? I pay an accountant to ensure that I pay the minimum amount of tax that the law requires. Every company does.

Company directors have a legal obligation to act in the best interests of their shareholders, and that is generally interpreted as meaning that they have to act to maximize profits. Directors who voluntarily paid more tax than they were obliged to, and by doing so reduced profits and hence shareholder dividends, could be personally liable to prosecution as a result.