678Relief where UK income tax borne by foreign estate: limited and discretionary interestsU.K.
(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 from the estate treated as arising under—
(i)section 654 (estate income: limited interests in residue), or
(ii)section 655 (estate income: discretionary 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,
B is the aggregate income of the estate for the tax year, and
C is the amount of United Kingdom income tax already borne by the aggregate income of the estate for the tax year.