640 Grossing-up of deemed income

640  Grossing-up of deemed income

(1)     The whole or any part of a capital sum which is treated under section 633 as income of the settlor for any tax year is treated as income of an amount equal to the sum or the part of the sum, grossed up by reference to the [trust rate] for that year.

(2)     The deductible amount is to be set off against the amount of tax charged on any amount treated under section 633 as income of the settlor for any year.

(3)     In subsection (2) the “deductible amount” is an amount equal to—

(a)     tax at the [trust rate] for the year on the amount treated under section 633 as the settlor's income,

(b)     so much of

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