Related Commentary  Related HMRC Manuals

166(1)  Subject to section 167A, section 165(4) shall not apply where the transferee is not resident in the United Kingdom.

166(2)  Section 165(4) shall not apply where the transferee is an individual if that individual–

(a)though resident in the United Kingdom, is regarded for the purposes of any double taxation relief arrangements as resident in a territory outside the United Kingdom, and

(b)by virtue of the arrangements would not be liable in the United Kingdom to tax on a gain arising on a disposal of the asset occurring immediately after its acquisition.

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