Commentary on Sections Part 10: Miscellaneous income Overview Section 946: Applicable rate for grossing up basic amounts of estate income
2378.This section provides for basic amounts of estate income to be grossed up, as appropriate, for the purposes of the sections charging income (section 941 for UK estates and section 942 for foreign estates) by reference to the rate at which tax is borne by the aggregate income of the estate. It is based on sections 699A and 701(3A) of ICTA. The aggregate income of the estate is defined in section 947. The corresponding rule for income tax is in section 663 of ITTOIA.
2379.Subsection (5) explains the interaction between “the relevant tax year” and “accounting period” for the purposes of this Chapter.