11(1)This paragraph applies if—U.K.
(a)a settlement has been created before 19th March 1991,
(b)on or after that date a person transfers property to the trustees otherwise than under a transaction entered into at arm’s length and otherwise than in pursuance of a liability incurred by any person before that date,
(c)the trustees are not resident or ordinarily resident in the United Kingdom at the time the property is transferred, and
(d)the transferor knows, or has reason to believe, that the trustees are not so resident or ordinarily resident.
(2)Before the expiry of the period of 12 months beginning with the relevant day, the transferor shall deliver to the Board a return which—
(a)identifies the settlement, and
(b)specifies the property transferred, the day on which the transfer was made, and the consideration (if any) for the transfer.
(3)For the purposes of sub-paragraph (2) above the relevant day is the later of—
(a)the day on which the transfer is made, and
(b)25th July 1991 (the day on which the Finance Act 1991 was passed).