Husband and wife own four investment properties(90% wife: 10% husband). Both are 40% taxpayers. They do not wish to transfer the properties into a limited company due to CGT on transfers. Instead, they wish to form a company which will pay a much reduced rental to husband and wife. The gross rents will be collected by the company for it's management.Therefore, the rental profits will be mostly taxed at 19% corporation tax rate, instead of the present 40% that the individuals are paying. This seems to good to be true. I am sure that HMRC will see this as some form of 'goodwill transfer' to the company and they may well question the relatively high 'management' charges. Any comments?