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(1)The charge to tax under section 649 on the amount of income arising in a tax year is subject to Part 8 (foreign income: special rules).
(2)For the purposes of section 830(1) (meaning of “relevant foreign income”) amounts charged to tax under section 649—
(a)are treated as arising from a source outside the United Kingdom if the estate is a foreign estate, and
(b)are treated as not arising from such a source if the estate is a UK estate.