§ Resolved,
That provision (including provision having retrospective effect) may be made imposing charges under the Taxation of Chargeable Gains Act 1992 on the beneficiaries and settlors of settlements where there has been a time when the trustees of the settlement, or of a settlement from which property comprised in the settlement directly or indirectly derives—
- (a) have not been resident or ordinarily resident in the United Kingdom, or
- (b) have fallen for the purposes of any double taxation relief
§ arrangements to be regarded as resident in a territory outside the United Kingdom.