I have 24 properties jointly with my wife totalling about £4.5 million with equity of about £1.85 million and capital gain of £1.21 million. The new rules which effectively set tax on revenue rather than on profit will almost wipe out my net income from property. How can I avoid this? A company would be good but the stamp duty land tax (SDLT) and capital gains tax (CGT) would be a huge initial cost.

There is not scope in this column to fully answer your question. One way to overcome the CGT problem in incorporating your property business is to claim incorporation relief (under TCGA 1992, s 162). However, you must fit into the requirements necessary to claim this relief, (e.g. working a significant number of hours per week to qualify as a business). Also, you may find difficulty shifting your existing mortgages into a limited company. And of course, there is the SDLT hurdle to overcome. There are ways of shifting rental income into a company without transferring ownership of the properties, but if you did so you may find yourself with not enough cash to pay your mortgages.