Income from Residential Solar Panels when that Person has Died

[SP11]

Hi

Have a client who died leaving a 100% share of a house to his spouse. The house had solar panels which the client sold excess electricity generated back to the grid. He opted not to receive that, and instead it was rolled up by the scheme administrator or energy company, it's not entirely clear at the minute.

The estate, for various unconnected reasons, has went on for a few years and the rolling up has continued during that time (unbeknown to us at the time). The spouse is now looking to start claiming this and had therefore brought the whole arrangement to our attention.

The income to our client in life appears to be non-taxable under S782A ITTOIA 2005 but reviewing Part 5 Chapter 5 of ITTOIA 2005 I cannot see anything which would extend this relief to the Personal Representatives. That being the case we would tax it at 20% on an accruals basis (to reiterate it has never been paid to the Estate) and include on an R185 at which point it becomes taxable on the surviving spouse who I do not believe can benefit from S782A on the basis that the income's nature has changed to that of 'Estate Income'.

Anyone have any thoughts on this?