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Liability of the personal representatives

After a person’s death, the property of the deceased is vested in the personal representatives (PRs) to enable them to manage and distribute the estate in accordance with the Will or the terms of intestacy. See the Personal representatives guidance note.

The PRs act as a single body and represent the estate as a separate legal entity. During the period of administration, income received by the personal representatives is assessed on the estate, and the PRs are responsible for paying the tax due.

Just like a UK resident individual, a UK resident estate is liable to income tax on its worldwide income (subject to double tax relief). A non-UK resident estate is liable to income tax on its income arising in the UK.

The residence status of an estate depends on the residence status of the PRs and the deceased:

1. •

   where all the PRs are UK resident, the estate is UK resident

2. •

   where all the PRs are non-UK resident, the estate is non-UK resident

3. •

   if