Arctic again

The properties — which comprise a substantial portfolio — are in the wife's name. The rents are collected by their company in which the wife has a majority and the husband a minority shareholding. The company pays the wife rental income of an amount equivalent to the mortgage interest that she pays on the properties. In addition to collecting the rent the company — for which husband and wife work full-time — carries out repairs and deals with tenants etc. However HMRC are now quoting TA 1988 s 21 and are saying that the rental income is assessable on the persons entitled to receive the income. This situation has existed for many years and I wonder if Olin Energy Systems is relevant here.
I should be most grateful if readers could offer any help or advice regarding the correct position in such a case.
Query T16...