Corporation Tax Act 2009 section 934

Charge to tax on estate income

Section 934 establishes that corporation tax applies to estate income received by corporate beneficiaries from deceased persons' estates, while providing an exemption for income derived from de minimis aggregate income.

• Corporation tax is charged on estate income arising from absolute, limited or discretionary interests in the whole or part of the residue of a deceased person's estate, whether a UK estate or a foreign estate.
• An exemption from corporation tax applies where estate income consists of a basic amount treated as paid from de minimis aggregate income — that is, aggregate income of the estate which is treated as bearing income tax at 0% under section 963(1A).
• An estate for these purposes means the estate of a deceased person, and estate income means income treated as arising under this chapter from an interest in the residue of such an estate.
• Where different parts of an estate are subject to different residuary dispositions, each part is treated as a separate estate for the purposes of calculating and charging estate income.