A Ltd traded for many years, and accumulated significant cash. In March 2016 subject to a detailed SPA it sold its entire undertaking other than accumulated cash but including all receivables, to an unconnected company B Ltd.
A Ltd was then put into Members Voluntary liquidation, and the accumulated cash paid to the members of A Ltd before 6th April 2016
In the event over the following years those receivables[including for example rates recoverable ] realised considerably more than the figures listed in the SPA and were collected by the liquidator of A Ltd
How is the surplus - arising out of the terms of the SPA and now payable by the liquidator of A Ltd to B Ltd - taxable in the hands of B Ltd?