A charge to tax arises:
(1) where the property comprised in a settlement or any part of that property ceases to be relevant property (whether because it ceases to be comprised in the settlement or otherwise)1; and
(2) in any other case, where the trustees of the settlement make a disposition2 as a result of which the value of relevant property comprised in the settlement is less than it would be but for the disposition3.
The amount on which tax is so charged is:
(a) the amount by which the value of relevant property comprised in the settlement is less
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