If the proposed demerger by Prudential of M&G goes ahead as set out in the proposal document dated 25 September 2019, s.2 Trusts (Capital and Income) Act 2013 will apply so that in most cases trustees will receive the M&G shares as capital.
The demerger document (at page 60) refers to the demerger being an exempt distribution under s.1075 Corporation Taxes Act 2010, which section confirms that “exempt distribution” means a distribution which is an exempt distribution by virtue of section 1076, 1077 or 1078.
Paul Saunders