I would tread very warily there. I would recommend an opinion from a specialist super compliance accountant and maybe have a tax opinion on it.
It would be very easy to breach there and if they decided it breached- there’s no discretion - 50% penalty
which makes getting opinions cheap. Indeed, if it were me - I would question if it’s worth the risk at all. These bastards write their own rules if you’re offside with them.
