TSEM7358 - Deceased persons: mixed residence personal representatives

If some but not all of听the personal representatives are not resident in the United Kingdom this may affect their liability to income tax. The rules for mixed residence personal representatives can be found at ITA07/S834.鈥�听

Mixed residence personal representatives are regarded as not resident for income tax purposes if when the deceased died, the deceased was:听

To 5 April 2025听

  • not resident in the UK or听听

  • not ordinarily resident in the UK*听or听听

  • not domiciled in the UK.听

From听6 April 2025听

  • not听resident听in the UK or听

听 听 听 听 not a long-term UK resident within the meaning of IHTA 1984听(IHTM)听

If none of the above applies to the deceased,听the personal representatives will be treated as wholly resident听in the UK for income tax purposes and the normal rules for assessing apply.鈥�听

Residence for CGT purposes听

The above rules apply for income tax purposes only.听厂别别鈥�CG30621鈥痮nwards for the rules about the status of personal representatives for capital gains tax purposes.听

*鈥疐or 2013/14 and later tax years not ordinary residence does not need to be considered.听