You'll find that tax loopholes are really a thing of the past. The ATO really has done a lot to stamp out aggressive planning. That being said, I think that it is still possible to tax plan effectively.
Your situation does have some legs but I would be careful as to how far you want to stretch it. It would be good to at least show some divvy yield imo. Either that or have a reasonably arguable position (a position more likely than not) which may protect you against interest and penalties if you end up being sunk.
