(1) This section shall apply where the trustees of a settlement, while continuing to be resident and ordinarily resident in the State, become at any time (in this section referred to as 'the time concerned’) on or after the 11th day of February, 1999, trustees who fall to be regarded for the purposes of any arrangements -
(a) as resident in a territory outside the State, and
(b) as not liable in the State to tax on gains accruing on disposals of assets (in this section referred to as 'relevant assets’) which constitute settled property of the settlement and fall within descriptions specified in the arrangements.
(2) The trustees shall be deemed for all the purposes of the Capital Gains Tax Acts -
(a) to have disposed of their relevant assets immediately before the time concerned, and
(b) immediately to have reacquired them,
at their market value at that time.
(3) Notwithstanding anything in that section -
(a) section 597 shall not apply where -
(i) the new assets are, or an interes
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