83 Trustees ceasing to be liable to U.K. tax.U.K.
(1)This section applies if the trustees of a settlement, while continuing to be resident F1... in the United Kingdom, become at any time (“the time concerned”) trustees who fall to be regarded for the purposes of any double taxation relief arrangements—
(a)as resident in a territory outside the United Kingdom, and
(b)as not liable in the United Kingdom to tax on gains accruing on disposals of assets (“relevant assets”) which constitute settled property of the settlement and fall within descriptions specified in the arrangements.
(2)The trustees shall be deemed for all purposes of this Act—
(a)to have disposed of their relevant assets immediately before the time concerned, and
(b)immediately to have reacquired them,
at their market value at that time.
Textual Amendments
F1Words in s. 83(1) omitted (with effect in accordance with Sch. 46 para. 112 of the amending Act) by virtue of Finance Act 2013 (c. 29), Sch. 46 para. 87