Corporation Tax Act 2009 section 937

Absolute interests in residue

Section 937 sets out the basis on which estate income is treated as arising in an accounting period where a company holds an absolute interest in the whole or part of the residue of an estate in administration.

• Income is treated as arising from a company's absolute interest in the residue of an estate if the company has an assumed income entitlement for the accounting period in respect of that interest.
• In addition, either a payment must be made in respect of the interest during the accounting period (before the end of the administration period), or the accounting period must be the final accounting period of the administration.
• In the final accounting period, no actual payment needs to be received — the taxable amount is simply equal to the assumed income entitlement for that period.
• Any income treated as arising under this section is classified as estate income for the purposes of the beneficiaries' income from estates rules.