What is the treatment following the demerger of Burberry from GUS and the new Biffa from Severn Trent.
I believe (from hearsay!) that, although capital treatment has been agreed by the Revenue, the receipt of the 'special dividend' of shares in Biffa/Burberry is income under trust law and therefore belongs absolutely to the beneficiary.
What is the tax effect on (a) the Trust [part disposal / cost reduction / nothing / something else] (b) the beneficiary [taxable income / a tax nothing with no tax to pay / something else]
The shareholder notes for GUS/Burberry do not give the full picture and the documents from SevernTrent/Biffa don't even mention the issue.
Can't find any guidance. Many thanks














