After checking HMRC's VAT pages, I believe that we would be on a hiding to nothing if we attempted to avoid VAT on a 'Membership Scheme' as the information appears to be quite clear on the VAT website:
5.1 How should I treat subscriptions for VAT purposes?
If your members pay a subscription to obtain or gain entitlement to any substantive benefits of membership, you must calculate the VAT due on the total amount of the subscription as set out in section 4 above.
The VAT liability of subscriptions depends on the liability of the membership benefits you supply in return. In most cases clubs supply a package of benefits so that your supply will have more than one element under the terms of paragraph 4.2 above.
If you make multiple supplies and the separate elements have different VAT liabilities, you must apportion the subscription charge (see paragraph 5.5 below).
Substantive benefits also include:
■ priority booking rights;
■ guaranteed seats;
■ discounts on admission charges; and
■ items with a resale value.
These benefits are considered to be substantive regardless of whether there is any cost to your organisation in supplying them and what that cost might be.
However, you can ignore benefits that have a nominal value, such as simple acknowledgements of support in the form of membership badges, flags or stickers, and listing of names in a programme or on a theatre seat or entrance.