Corporation Tax Act 2009 section 939

Limited interests in residue

Section 939 sets out the circumstances in which estate income is treated as arising in an accounting period from a company's limited interest in the residue of an estate.

  • Estate income arises where a payment is made in respect of a limited interest during an accounting period and before the end of the administration period (Case A)
  • Estate income also arises in the final accounting period where a sum remains payable in respect of the interest at the end of administration (Case B)
  • Where the interest ceases before the final accounting period, income is recognised if sums are paid later or remain payable at the end of administration (Case C)
  • This section does not apply to successive limited interests covered by section 957, but income arising under either section 939 or section 957 counts as estate income

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