Family formula

My clients Mr and Mrs N have recently separated. Mr N has left the family home where his wife remains with their two children aged 11 and 21. He has also given another property a shop to Mrs N the idea here being that the rental income should go to the children for their school fees maintenance etc.

The rental income goes into Mrs N’s bank but she uses this income for the children according to Mr N’s wishes. In the near future Mrs N will start to receive income from a new employment and will be liable to tax on this.

I am thinking of dividing the net rental income from the shop between the two children who would then be liable for tax on any income in excess of their personal allowances which are currently unused.

Is this...