You are confusing Capital Gains Tax with Income Tax.
If the trust is not wound up or restructured then there is no deemed sale of assets and therefore no CGT. If the trust is wound up or if it is restructured this would result in a capital gain for the trust members which is taxable. So the members of the trust would receive a distribution of assets from the trust which is then liable for CGT.
A trust can hardly be said to be not paying tax if it has no capital gains to tax. Trusts also pay income tax on their earnings as do the members of the trust when there is a distribution of earnings from the Trust.
