Commentary on Sections Part 10: Miscellaneous income Overview Section 960: Relief in respect of tax relating to absolute interests
2427.This section provides for relief if income, which has borne United Kingdom tax, arises to a company with an absolute interest in the residue of a foreign estate. It is based on section 696(7) of ICTA. The corresponding rule for income tax is in section 677 of ITTOIA.
2428.Subsection (2) contains the formula for calculating the relief where a claim is made. The labels in section 696(7)(a) and (b) of ICTA – “the deemed income” and “the aggregate income” respectively – were added as explanatory aids in the course of the ICTA consolidation. These labels are not retained.