38 Income-based carried interest: persons coming to the UK

38  Income-based carried interest: persons coming to the UK

(1)     In section 809EZA of ITA 2007 (disguised investment management fees: charge to income tax), after subsection (2) insert—

“(2A)     Subsection (2B) applies instead of subsections (1) and (2) where—

(a)     one or more disguised fees arise to an individual in a tax year (“the relevant tax year”) from one or more investment schemes (whether or not by virtue of the same arrangements),

(b)     the disguised fees consist of carried interest which is income-based carried interest,

(c)     the individual is UK resident

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