I4.533 UK estates and foreign estates
For the meaning of residence, ordinary residence and domicile, see Division E6.1.
The tax treatment of income of a beneficiary of the estate during the administration period depends on whether the estate is a UK estate or a foreign estate, which in turn depends on the residence status of the personal representatives PRs).
Where at least one of the PRs is resident in the UK and at least one other is not, for income tax purposes either all the PRs are treated as resident in the UK or all of them are treated as not resident in the UK, irrespective of their residence status in respect of their personal incomes. If the deceased person was, at the time of his death, resident or domiciled in the UK, any non-resident personal representative is treated as resident in the UK for this purpose. If this condition is not met, any UK resident personal representative is treated as non-resident1.
There are changes to the domicile
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