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HMRC internal manual

International Manual

Double Taxation applications and claims: Applicants/claimants: Estates and deceased persons: Claims by personal representatives

Personal representatives can claim on income arising up to the date of death (INTM340040), and may be able to claim on income arising during the administration period of the estate (INTM340050). Income arising after the administration period of an estate has ceased is the property of the beneficiaries and any claim should be made by the beneficiaries. An exception to this is when the will of the deceased creates a discretionary or contingent trust, in which case it may be difficult to identify the beneficial owner. However, we may be able to accept a claim by trustees of non-resident trusts (see INTM339500).