Section 677 | Relief where UK income tax borne by foreign estate: absolute interests
From legislation.gov.uk
15 July 2026
(1)This section applies if—
(a)an estate is a foreign estate in relation to a tax year,
(b)United Kingdom income tax has been charged on a person for the tax year on estate income treated as arising from the estate under section 652 (estate income: absolute interests in residue), and
(c)United Kingdom income tax has already been borne by part of the aggregate income of the estate for the tax year.
(2)If the person makes a claim under this section, the income tax charged on the person on that estate income is to be reduced by an amount equal to—
Formula
where—
T is the income tax charged on the person,
A is so much of the aggregate income of the estate as has already borne United Kingdom income tax for the tax year, and
B is the aggregate income of the estate for the tax year.
(3)The tax reduction under this section is given effect at Step 6 of the calculation in section 23 of ITA 2007.F1