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HMRC internal manual

International Manual

Double Taxation applications and claims: Applicants/claimants: Estates and deceased persons: Pre-death income

Any claim on income arising to the deceased up to the date of death must be made by the personal representative, based on the deceased’s entitlement to claim at the time the income arose. A double taxation claim must therefore be under the double taxation agreement with the country in which the deceased was resident, even if the personal representative is resident in a different country (including the United Kingdom).

You cannot accept a claim by a beneficiary on pre-death income. Claims may be made by a beneficiary who is also a personal representative; these can be accepted on the basis of the beneficiary’s capacity as a personal representative.