Section 961 — Corporation Tax Act 2009: Relief in respect of tax relating to limited or discretionary interests

Relief in respect of tax relating to limited or discretionary interests 961 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— T × A - C B - C 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.