Commentary on Sections Part 10: Miscellaneous income Overview Section 939: Limited interests in residue
2365.This section deals with estate income relating to limited interests. It is based on section 695(2) and (3) of ICTA. The corresponding rule for income tax is in section 654 of ITTOIA.
2366.The section sets out the basis on which estate income is treated as arising in an accounting period for limited interests in residue. The section reflects the need to deal with accounting periods before the final accounting period. Also, a limited interest might cease in an accounting period before the final accounting period and sums might be paid in respect of that interest in a later accounting period; so that situation has to be provided for.