Commentary

I4.544 Tax on estate income—UK estates

IHT, trusts and estates

I4.544 Tax on estate income—UK estates

I4.544 Tax on estate income—UK estates

A beneficiary is charged to income tax for a tax year, or corporation tax for an accounting period, on the basic amount of estate income applicable to the beneficiary's interest grossed up by reference to the applicable rate for the relevant tax year (see below)1. The basic amount is determined by the rules applicable to the nature of his interest in the residue of the estate (see I4.546–I4.550). The gross amount is deemed to have suffered income tax at the applicable rate2.

By concession (A14 — see Part G2) a beneficiary who, for a year of assessment, is

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