Trevor S, thank you for oyour further thoughts. I knew there was something somewhere in the guidance. Here, from VAT notice 7009.
2.2.5 TOGC where the seller is not registered for VAT
There can be a TOGC where the seller is not registered for VAT. For example, because the seller is trading below the registration limit. The sale of a non VAT-registered business which includes trading stock, the value of which might otherwise take the trader over the registration limit, will not do so because it can be treated as a TOGC and therefore not a supply.
So the Company can do a TOGC on liquidation provided the executors continue to trade for a while - two or three weeks, presumably, will be enough?
Then they can distribute the assets to the beneficiaries, and nobody need ever worry about VAT?