Commentary on Sections Part 10: Miscellaneous income Overview Section 948: Assumed income entitlement
2386.This section explains the new concept of the “assumed income entitlement”. It is based on section 696(3A), (3B) and (5) of ICTA. The corresponding rule for income tax is in section 665 of ITTOIA.
2387.The concept of “assumed income entitlement” has been introduced as a tool for calculating the basic amount of estate income for absolute interests. It is similar to the “aggregated income entitlement” in section 696(3B) of ICTA but applies in a more straightforward way.
2388.Step 4 in subsection (1) deals also with situations where a beneficiary liable to corporation tax was, at some earlier point during the administration period, chargeable to income tax. It also deals with other situations where a non-UK resident beneficiary becomes UK resident, when the estate is a foreign estate.