539. Grossing up of net income and aggregate income.

The applicable rate by reference to which a basic amount of estate income1 is grossed up in a UK or foreign estate2 depends on the rate at which income tax is borne by the aggregate income3 of the estate for the tax year4 (or relevant tax year if the beneficiary is a company5).

If the aggregate income of the estate all bears income tax at the same rate, the applicable rate is that rate6.

If different parts of the aggregate income of the estate bear income tax at different rates, and the same rate applies to all the income from which