Income Tax (Trading and Other Income) Act 2005 section 676

Apportionments

Section 676 requires just and reasonable apportionments to be made when successive interests in a residuary estate do not cover exactly the same portion of that estate.

• Where successive interests apply to different parts of a residuary estate, just and reasonable apportionments must be made
• This also applies where one interest covers the whole estate but a successive interest covers only part of it
• The apportionment rule applies across all the successive interest provisions in sections 671 to 675
• Only the proportionate share of residuary income and net amounts relevant to the affected part of the estate is used in the calculations