Julian and Samantha have resigned from their jobs in order to work together full-time on designing a software package that detects plagiarism in student assignments. They have already been able to sign highly profitable deals with a number of Universities, meaning that they are very confident that they will make a big profit each year for at least the next five years. They have three adult children, who are university students and have low-income jobs. Their highest priority is to minimise the tax that they have to pay on these profits. Given this priority and given their current circumstances, the best structure for their business (out of the following three options) is likely to be:

A. A discretionary trust, where both the income from the trust property and any right to the trust property itself is distributed to the beneficiaries at the discretion of the trustee.

B. A unit trust, with Julian and Samantha each owning half of the units in the trust and having a fixed right to half of any income derived from the trust property and to half of the trust property itself.

C. A partnership, because they will be able to offset business losses against their personal income from other sources in order to reduce their tax.