Demergers for IIP Beneficiaries (GUS/Burberry - SevernTrent/Biffa)

Postby dmplondon on Fri Oct 20, 2006 5:19 am

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
dmplondon
 
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