Estate income and s.669 relief

[probate_slave]

As administrator I am claiming s. 669 ITTOIA 2005 relief for qualifying estate income passing to absolute residiary beneficiaries, all higher rate taxpayers. Could someone kindly clarify what is meant by VE ("the value of D's estate") in the legislation?

I am assuming that it refers to the total chargeable estate after exemptions and reliefs (box 108 on IHT400), rather than the net estate after liabilities (box 91) or something else. If, for instance, half the estate were left to charity, it would seem illogical and unfair to halve the relief by using the box 91 figure.