Gift of royalty rights to Company

I have clients who I took over a year or so ago. They are in the music business and have for many years traded as a partnership for their royalty income and as a Company for gigs/music creation/etc.

The reason they kept it separate was because they thought they could not bring the royalties into the Company which after talking to PRS etc they now know is not true.

So from 6/4/09 the partnership is no longer and all income goes into the Company.

The question is what is best to do for tax?

I have asked the Client for details of the royalty income over the last 3 years and it comes to £120k. So as a base point for a goodwill value at say 2.5 x annual amount that gives £100k.

The partners would want this credited to their loan account. That would appear to scupper any deferral of the CGT and would give rise to around £3.5k of tax. This makes it not really worth it as the two partners are not higher rate tax payers so are quite happy to top up their personal accounts sometimes with dividends without paying the higher rate tax. Thus having a loan to draw against would not be a tax advantage as it would cost £3.5k. they are unlikely to reach the higher rate for many years.....

I am swaying towards bringing it in at a value under MV say £35k which by my calculation gives a small liability:

Market value 100k

Less: deferred (100k minus amount received) 65k

Gain 35k

x5/9= 19,444

Under exemption.

Any thoughts?