Tax efficient company structure

Tax efficient company structure. I am returning to contracting again and seek your opinion on the following proposal

My wife and I will set up a new company to provide services associated with information management & software development; managing rented accommodation and careers guidance. The major revenue stream will be working in information management & software development. Managing rented accommodation will be a minor shared role and careers guidance may occasionally be undertaken by my wife but this is by no means certain.

I will be an employee paid market rate for permie (about £40k) plus travelling expenses to client sites (IR approved mileage rates) plus subsistence as and when incurred. As a business analyst I expect contracts to be of many months duration. I do expect gaps between contracts; should the gap be large I will be laid off

My wife will be sole director and shareholder. She will provide £10,000 of working capital to fund start-up period and gaps between contracts. Her active role will be job search / research

My role will be business analyst, available on contract, and company administrator (I will be company secretary)

I expect some 75% of revenue to be spent on my salary, NIC and pension

Will it be reasonable for the balance to be split between retained profit and dividend or will my entire revenue stream be caught by IR35?

We await the outcome of the S660A appeal but do you think this company structure will fall foul of S660 regulations?

When the company is finally closed down we will take professional advice on the best mechanism to use

Your comments, suggestions and other options would be appreciated

-- alandjones