Corporation Tax Act 2009 section 957

Holders of limited interests

Section 957 explains how estate income is recognised for corporation tax purposes where successive limited interests in the residue of an estate are held by different persons during the administration period.

• Where two or more interests in the residue of an estate are held successively by different persons and the earliest interest is a limited interest (each later interest arising other than by death), special rules determine when income is treated as arising
• Case A: income arises where a payment is made in respect of one of the interests during the limited holder's accounting period and before the end of the administration period, and the limited holder is entitled to receive it
• Case B: income arises in the final accounting period where a sum remains payable at the end of the administration period and the limited holder is entitled to receive it
• Case C: income arises where the last of the successive interests ceases before the final accounting period, and a payment is either made in a later period or remains outstanding at the end of the administration period, provided the limited holder is entitled to receive it