SolvedTSEM7358 | Deceased persons: mixed residence personal representatives
From HM Revenue & Customs · Trusts, Settlements and Estates Manual
If some but not all of 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.
Mixed residence personal representatives are regarded as not resident for income tax purposes if when the deceased died, the deceased was:
To 5 April 2025
not resident in the UK or
not ordinarily resident in the UK* or
not domiciled in the UK.
From 6 April 2025
not resident in the UK or
If none of the above applies to the deceased, the personal representatives will be treated as wholly resident in the UK for income tax purposes and the normal rules for assessing apply.
Residence for CGT purposes
The above rules apply for income tax purposes only. See CG30621 onwards for the rules about the status of personal representatives for capital gains tax purposes.
* For 2013/14 and later tax years not ordinary residence does not need to be considered.