Corporation Tax Act 2009 section 947

Aggregate income of the estate

Section 947 defines how to calculate the "aggregate income of the estate" for a tax year, which is a key figure used throughout the rules on taxing income from deceased persons' estates received by corporate beneficiaries.

• The aggregate income of the estate is the total of all income received by the personal representatives in their capacity as such, including UK-taxed income, foreign-source income (treated as if it were UK income), stock dividends, certain close company loan releases, and life insurance contract gains.
• When calculating UK-source income, allowable deductions are taken into account; for foreign-source income, any deductions that would have been available had the income been subject to UK income tax are similarly deducted from the full amount actually arising.
• Two categories of income are excluded from the aggregate: income to which any person is or may become entitled under a specific disposition (such as a gift of specific property under a will), and income from property that devolves on the personal representatives other than as assets available for paying the deceased's debts.
• A "specific disposition" means a gift of specific property under a will, including intestacy chattels under the Administration of Estates Act 1925 and equivalent dispositions under foreign law, but it does not include real property (or heritable estate in Scotland) that forms part of a residuary gift described in general or specific terms.