Profit or dividend?

I act for a limited company client which provides extremely specialist advice to other businesses (around 50 per annum) and charges them a fee representing an agreed percentage of financial savings achieved. The client incurs minimal operating expenses as the business is run from home by its director/shareholder.
My client wishes to receive fees from its customers in the form of a dividend (on which no further tax would be due) and has suggested the following structure.
My client company would subscribe for new redeemable ordinary shares in the customers' companies such shares carrying the right to be redeemed at par value together with payment of a dividend representing the agreed 'fee' for advice rendered.
The customer would receive no tax relief on the dividend paid but my client would incur no tax — these factors being reflected in the level of the 'fee' charged and the...