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Corporation Tax Act 2009
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Corporation Tax Act 2009, Section 961 is up to date with all changes known to be in force on or before 08 November 2024. There are changes that may be brought into force at a future date. Changes that have been made appear in the content and are referenced with annotations.
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- Blanket amendment words substituted by S.I. 2011/1043 art. 3 4
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- s. 322(2A)(zb) inserted by 2016 c. 24 s. 73(5)
- s. 1058B(5)(ea) inserted by 2023 c. 20 Sch. para. 57
- s. 1094(2A)-(2C) inserted by 2012 c. 14 Sch. 3 para. 13(3)
- s. 1106(4A)-(4C) inserted by 2012 c. 14 Sch. 3 para. 14(3)
961Relief in respect of tax relating to limited or discretionary interestsU.K.
This section has no associated Explanatory Notes
(1)This section applies if—
(a)United Kingdom corporation tax has been charged on a company for an accounting period on estate income from an estate treated as arising under—
(i)section 939 (estate income: limited interests in residue), or
(ii)section 940 (estate income: discretionary 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,
B is the aggregate income of the estate for the relevant tax year, and
C is the amount of United Kingdom income tax already borne by the aggregate income of the estate for the relevant tax year.
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