Corporation Tax Act 2009

957 Holders of limited interests

(1) This section applies if—

(a) two or more interests in the whole or part of the residue of an estate are held successively during the administration period by different persons,

(b) the earlier or, if there are more than two, the earliest of the interests is a limited interest, and

(c) each later interest arises or is created on the cessation of the previous interest otherwise than by death.

(2) Income is treated as arising from a limited interest in the whole or part of the residue of the estate in an accounting period in cases A, B and C.

(3) Case A is where—

(a) one of the successive interests subsists at the beginning of the accounting period of a company which has or has had one of the interests which is a limited interest (the “limited holder”),

(b) a sum is paid in respect of one of the interests in that period and before the end of the administration period, and

(c) the limited holder is entitled to receive the payment.

(4) Case B is where—

(a) the accounting period of a limited holder is the final accounting period,

(b) one of the successive interests subsists at the beginning of that period,

(c) a sum remains payable in respect of one of the interests at the end of the administration period, and

(d) the limited holder is entitled to receive the payment.

(5) Case C is where—

(a) the accounting period of a limited holder is a period before the final accounting period,

(b) the last of the successive interests ceases in the accounting period,

(c) a sum is either—

(i) paid in respect of one of the interests in a later accounting period but before the end of the administration period, or

(ii) remains payable in respect of it at the end of the administration period, and

(d) the limited holder is entitled to receive the payment.