Distributions by executors to beneficiaries cannot possibly be a supply for VAT purposes. Can they? There's no consideration.And even if you could justify it, wouldn't you still have an unregistered organisation (the executors) making supplies of goods worth in excess of the VAT registration threshold?
vbnb22000It is clear from the European Court of Justice (CJEU) case of Apple & Pear Development Council (VBNB72200) that if an activity involves the making of supplies of services for no consideration that these cannot be seen as taxable supplies. An activity that involves making no taxable supplies cannot be business.