Section 166 | Gifts to non-residents.

(1)Subject to section 167A, section 165(4) shall not apply where the transferee is not resident in the United Kingdom.^F1F2

(2)Section 165(4) shall not apply where the transferee is an individual ... if that individual ... —^F3

(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^F4

(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.