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(1)Section 528 does not apply if, when the chargeable event occurs or at any time during the policy period, the policy is or was held—
(a)by a non-UK resident trustee,
(b)by non-UK resident trustees, or
(c)by a foreign institution.
(2)Section 110 of FA 1989 (residence of trustees) applies for the purposes of subsection (1)(b) despite section 110(6) of that Act (which provides that it only applies for 1989-90 and subsequent tax years).
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