IHTM30115 | The settlor: settlement made before 11 December 1974
From HM Revenue & Customs · Inheritance Tax Manual
Under the settlor is not liable under in relation to a settlement made before 11 December 1974 if
the trustees were resident in the United Kingdom when the settlement was made and
the trustees have not been resident in the United Kingdom at any time between 10 December 1974 and the time of the transfer.