This section applies where—
a transfer of assets to which section 140A(1A) or 140C(1A) applies has taken place,
the transferor and the transferee (or each of the transferees) are each resident in a relevant state,
they are not all resident in the same relevant state, and
the transfer does not constitute or form part of a scheme of reconstruction within the meaning of section 136.
Where this section applies, the transfer shall be treated for the purposes of section 136 as if it were a scheme of reconstruction.
Where section 136 applies by virtue of subsection (2) above section 136(6) (and section 137) shall not apply.