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»Ê¹ÚÌåÓýappre are important differences between the treatment accorded to interests in United Kingdom estates and interests in foreign estates (see TSEM7682-TSEM7684).

A United Kingdom estate is one where

• the income of the estate includes only income chargeable by deduction or otherwise to UK income tax in the hands of the personal representatives, and
• the personal representatives are not entitled to claim exemption from UK tax by reason of their being not resident in the UK.

»Ê¹ÚÌåÓýapp statutory definition of the term is in ITTOIA/S651 subsections (1), (2) and (3) for non-corporate beneficiaries, and in CTA 2009/S936 subsections (1), (2) and (3) for corporate beneficiaries.

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