Income Tax (Trading and Other Income) Act 2005

677 Relief where UK income tax borne by foreign estate: absolute interests

(1) This section applies if—

(a) an estate is a foreign estate in relation to a tax year,

(b) United Kingdom income tax has been charged on a person for the tax year on estate income treated as arising from the estate under section 652 (estate income: absolute interests in residue), and

(c) United Kingdom income tax has already been borne by part of the aggregate income of the estate for the tax year.

(2) If the person makes a claim under this section, the income tax charged on the person on that estate income is to be reduced by an amount equal to—

where—

• T is the income tax charged on the person,

• A is so much of the aggregate income of the estate as has already borne United Kingdom income tax for the tax year, and

• B is the aggregate income of the estate for the tax year.