261 Section 260 relief: gifts to non-residents.U.K.
(1)Section 260(3) shall not apply where the transferee is neither resident nor ordinarily resident in the United Kingdom.
(2)Section 260(3) shall not apply where the transferee is an individual who—
(a)though resident or ordinarily 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.