Readers’ forum: Would capital receipt be subject to CGT?

An unincorporated club is making a distribution mainly from the proceeds of selling a property on which the club will pay corporation tax on its capital gain. The full circumstances are shown below in my original question (Q 20 360):

‘Are the members of an unincorporated club taxable when the club distributes unwanted funds to the members in accordance with the club constitution which caters for such a distribution pro-rata to years of membership?

• No member has paid an initial contribution.
• Members pay an annual subscription.
• There is a surplus from mutual trading but much of the distribution will be from the sale of the club premises.
• The club will be liable for CT on the gain.

The premises were used by the members except that there was a flat above with shared access rented to tenants. The club has paid CT on the net rental income.

Would...