Income sprinkling is indeed a strategy that is practically only available to high income earners.  Here is how avoidance strategies work, generally.  Professional tax accountants at various degrees on the ethical scale intimately understand the tax code, and their job is to develop strategies for avoiding tax, and this is done for the benefit of high income earners, who assume the burden of the cost of performing this intellectual work.  Poor people can't pay for it.  Once a strategy is devised and used successfully, everyone in the profession gets to know it. The government, for its part,  is constantly trying to combat these tax avoidance strategies, which are legal.  That's how the game is played. Surely income sprinkling to 'not at arms length' shareholders, who receive a return from a business, and have not actually made any financial investment, is purely an arrangement set up to save tax, and serves no other purpose.  And ... is only used by high income earners.