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HMRC internal manual

Trusts, Settlements and Estates Manual

Deceased persons: interests in residue: practical and computational aspects - foreign estates

Where a beneficiary has an absolute limited or discretionary interest in a foreign estate the deemed income is assessable as income from foreign securities. This means that there can be basic rate as well as higher rate liability.

The beneficiary will not be entitled to claim a repayment of tax in respect of an interest in a foreign estate.

In any case where the beneficiary has an interest in the residue of a foreign estate (or what may be a foreign estate), refer the case to HMRC Trusts Nottingham.