Part 10

Miscellaneous income
Chapter 3

Beneficiaries' income from estates in administration

Relief where foreign estates have borne UK income tax

Relief in respect of tax relating to absolute interests
960
1
This section applies if—
a
United Kingdom corporation tax has been charged on a company for an accounting period on estate income treated as arising from an estate under section 937 (estate income: absolute interests in residue),
b
the estate is a foreign estate in relation to the relevant tax year, and
c
United Kingdom income tax has already been borne by part of the aggregate income of the estate for the relevant tax year.
2
If the company makes a claim under this section, the corporation tax charged on the company on that estate income is to be reduced by an amount equal to—
T × A/B
where—
T is the corporation tax charged on the company,
A is so much of the aggregate income of the estate as has already borne United Kingdom income tax for the relevant tax year, and
B is the aggregate income of the estate for the relevant tax year.