When enquiries are made regarding the repayment of these 'loans', it will surely be established that these 'loans' were never intended to be repaid - which they weren't.
When the individuals try to explain why they won't be repaying the 'loan', it could well become apparent that these 'loans' were nothing more than fraudulent attempts to avoid paying tax - once they've been established as fraudulent, it could then become a matter of tax evasion, rather than tax avoidance.
Here's how it could go:
HECTOR: "So, Doddsie - gonnae pay this loan back, mate?"
DODDSIE: "Naw".
H: "How no, likesay?"
D: "I was telt I widnae have tae pay it back".
H: "You were telt you widnae have tae pay a loan back? Whae telt ye that, like?"
D: "Erm, Rangers...and my agent - they said it would be alright - they said they'd been daein it for ages".
H: "ORLY?"
Make no mistake, folks - this is tax fraud.
Loans, my arse!