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HMRC internal manual

International Manual

Double Taxation applications and claims: Applicants/claimants: Estates and deceased persons: What happens if a life tenant of a Will trust dies

When a life tenant dies we may have to consider the effect of the Apportionment Act 1870. The Will can state that the terms of the Act are not to apply. Otherwise, the effect of the Act is to treat income accrued before, but paid after, the date of death as income of the personal representatives of the life tenant.

Any income which accrues after the date of death of the life tenant is not the income of the estate but is income of the persons entitled to it, under the Will trust, on the death of the life tenant.