In the case of a foreign estate, F3the charge to tax under section 649 is a charge on the full amount of estate income treated as arising in the tax year.

That amount depends on whether the estate income arising in the tax year is paid from sums within section F1680(4) (sums treated as bearing income tax).

So far as the estate income is paid from such sums, that amount is the basic amount of that income for the tax year grossed up by reference to the applicable rate F2... (see section 663).

That gross amount is treated as having borne income tax at that rate.

So far as the estate income is not paid from sums within section F1680(4), the amount of estate income treated as arising in the tax year is the basic amount of that income for that year.