Appointment of residue to Non resident Trustees

My client’s will appoints UK executors but Jersey trustees of the residuary will trust for the widow.
I consider that a s 80 exit charge should not apply on the appointment of assets to the Jersey trustees, once the residue is ascertained.
Any views?
Sarah Godfrey

If the executors appointed under the will are to also act as trustees of any will trust (and are UK resident), and the executors become trustees, property of the residuary estate becomes settled property in which case TCGA 1992 s.80 will then apply on the replacement of the UK resident trustees by non-UK resident trustees.

However, as seems to be the case, if the executors are not to act as trustees of any will trust then on ascertainment of residue the executors will be no more than bare trustees for the Jersey trustees in which case TCGA 1992 s.80 is not in point.

Malcolm Finney