Demergers: direct demergers: CGT treatment: trustees
Where the shares in the distributing company are held by trustees, the treatment for Capital Gains Tax purposes depends upon:
- The law governing the trust (for example, England & Wales or Scotland).
- The type of interests which the beneficiaries have (interests in possession or not).
- The type of exempt demerger (direct or indirect).
- Whether the demerged or issued shares are received as income or capital in the hands of the trustees for the purposes of trust law.
In the case of a bare trust, see CG34300+, the normal rules for individuals apply, see CG33920.