Thank you for your reply and does the Deed have a special name ?
You say CGT is payable but if the residential property is rented out in some cases these can be incorporated with no CGT I understand.
A recent case Ramsay V HMRC 2012 no CGT was payable as it was deemed to be run like a business and Ramsey spent at least 20 hours per week and provided some services such as garden cutting etc.
I would appreciate your thoughts on how active the landlord needs to be?
Full management by the landlord including all maintenance work checking rental payments, protection of deposit, all correspondence with the tenant.
Appreciate your thoughts on what the HMRC will want to see to allow you to incorporate with no CGT payable?