On a trust becoming dual resident, there is a deemed disposal and reacquisition, by the trustees, at market value at that time, of all their relevant assets. ‘Relevant assets’ means all those assets which are settled property and which are covered by the double taxation relief arrangements. This provision operates at the time, ‘the time concerned’ that trustees of a settlement become dual resident (that is, even though they remain UK resident for UK tax purposes generally, they become also resident in some other territory under the laws of that territory), and by virtue of double taxation relief arrangements they are consequently not liable to UK tax on gains.

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