Corporation Tax Act 2009 (c. 4)

Part 10 U.K. Miscellaneous income

Chapter 3 U.K. Beneficiaries' income from estates in administration

Relief where foreign estates have borne UK income tax U.K.

960 Relief in respect of tax relating to absolute interests U.K.

(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—

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.