Capital gains tax on residential property

Residential property long held in a company

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My aging brother and sister clients were gifted share tranches of their parents' residential property investment company between 1982 and 1985 and ultimately inherited  the balance of the shares in 1999.  The residential properties are in a row and, therefore, have useful development value.  The siblings now wish to dispose of their holdings and have received an offer for their company.  Will the 20% CGT rate apply to the disposal of their shares or is there some avoidence rule regarding enveloped property (all the property is let, so I'm not referring to ATED) that leaves them open to the 28% charge?

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