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HMRC internal manual

International Manual

HM Revenue & Customs
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Double Taxation applications and claims: Applicants/claimants: Estates and deceased persons: Introduction

What an estate is

When a person dies, the total of all of the property which he or she owns at the date of death is his or her ‘estate’.

Claims you may receive in connection with estates

You may receive claims under double taxation agreements from personal representatives of deceased persons and from beneficiaries of estates. (See INTM340020 for definitions of these terms.)

  • Claims by the personal representatives of a deceased person will be made because

    • the deceased was entitled to relief during their life on income paid before death, and/or
    • the personal representatives may be entitled to claim relief on income arising to the estate.
  • Claims and applications by beneficiaries of an estate will be made because the beneficiary has received, or expects to receive, income taxed in the UK on which they may be entitled to claim relief under a Double Taxation treaty. The estate from which the income is paid to the beneficiary may be resident in the United Kingdom, or may be resident in another country. Guidance on claims by beneficiaries of foreign estates is given at INTM367550.