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HMRC internal manual

International Manual

Double Taxation applications and claims: Applicants/claimants: Estates and deceased persons: Attorney administrators

An attorney administrator is appointed by the personal representatives of a deceased person to act on their behalf. The attorney administrator is empowered to carry out administrative duties for the personal representatives, including taking out a UK grant of representation and making claims. However, we need to consider entitlement to relief on the basis of the actual personal representatives, or of the deceased if the income arose before the date of death. Therefore a UK resident attorney administrator claiming on behalf of non-resident personal representatives might make a successful claim on administration period income whereas a non-resident attorney administrator acting for UK resident personal representatives could not claim.