Section 957 — Corporation Tax Act 2009: Holders of limited interests

Holders of limited interests 957 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.