The important point to consider is that the Advance Ruling confirmed that there should be no immediate tax implication to us resulting of the distribution.
I'm happy then with the 'tax-free gift', though I'm aware that a capital property is always bearing a latent tax and that the Administration will take its due sooner or later, when I finally dispose of the 'gift'.
So at the end, there are never a complete gift, since Big Brother iwill take his share, surely and undoubtedly, at worst at my death!
GLTA.
BaBe.