This section applies in relation to a settlement if—
in a particular tax year, the settlement ceases to exist,
two or more beneficiaries ("the recipients") in the year receive capital payments from the trustees, and
at least one of the recipients is, and at least one is not, a non-resident beneficiary.
Those capital payments, so far as received by such of the recipients as are non-resident beneficiaries, are not within section 87D(2).
In this section "non-resident beneficiary" means a beneficiary who at all times in the year is not resident in the United Kingdom.