Section 84 Acquisition by dual resident trustees.

the new assets are, or the interest in them is, acquired by the trustees of a settlement,

at the time of the acquisition the trustees are resident F1... in the United Kingdom and fall to be regarded for the purposes of any double taxation relief arrangements as resident in a territory outside the United Kingdom,

the assets are of a description specified in the arrangements, and

were the trustees to dispose of the assets immediately after the acquisition, the trustees would fall to be regarded for the purposes of the arrangements as not liable in the United Kingdom to tax on gains accruing to them on the disposal.