Income Tax Act 2007 section 640

Small holdings: personal representatives

Section 640 provides that personal representatives administering a deceased person's estate are excluded from the accrued income scheme where the nominal value of securities they hold does not exceed £5,000.

  • Personal representatives are treated as excluded transferors or excluded transferees if the nominal value of securities in the estate does not exceed £5,000 on any day in the relevant tax year or the preceding tax year.
  • The £5,000 threshold applies separately to transfers with accrued interest, transfers without accrued interest, transfers with unrealised interest, and transfers of variable rate securities.
  • Unlike the equivalent rule for individuals, there is no requirement to combine the personal representatives' holding with anyone else's when testing against the £5,000 limit.
  • When a person dies, the vesting of securities in their personal representatives is not itself a transfer for accrued income purposes, but any subsequent transfer by the personal representatives may be.

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