12.3.1 First principles

It is important for the PRs to distinguish between income of the administration period and income of the deceased prior to death. Income which is due before death is that of the deceased, whilst income due after death is that of the estate. The PRs are accountable for income tax owed by the deceased at the date of death and for income tax due on income of the administration period.

See 11.3.1 for a discussion as to when dividends, interest and rental income become due for tax purposes.

Law: ITA 2007, s. 11, 479

Cases: IR Commrs v Henderson’s Executors (1931) 16 TC 282; Potel v IR Commrs (1971) 2 All ER 504

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