If trustees are claiming relief for overseas tax they will
usually regard expenses as paid out of UK income. This means they
can certify the overseas income to the beneficiaries under
ICTA88/S809 (TSEM3680).
They may sometimes regard expenses as paid from overseas
income. This could be because there is not sufficient UK income to
cover the expenses. Or maybe certification is not advantageous to
the beneficiary.
Trustees cannot certify, under S809, the overseas income they
set against the expenses.
