Commentary on Sections Part 10: Miscellaneous income Overview Section 951: Reduction in share of residuary income of estate
2396.This section provides that the share of the residuary income of the estate of a company with an absolute interest is reduced at the end of the administration period in certain circumstances. It is based on section 697(2) and (3) of ICTA. The corresponding rule for income tax is in section 668 of ITTOIA.
2397.Until it was repealed by ITA 2007, section 4(1) of ICTA provided that sums paid during (or on completion of) the administration period were to be grossed up by reference to the basic rate for the tax year in which it was paid in the case of UK estates. Subsection (5) provides that, for the purposes of subsection (1)(b) the basic rate is used when grossing up these sums. See Change 72 in Annex 1.