43 Carried interest
Finance (No 2) Act 2015 (2015 c 33) | Legislation

Income tax and capital gains tax

43  Carried interest

(1)     In Part 3 of TCGA 1992 (individuals, partnerships, trusts and collective investment schemes etc), after section 103K insert—

“Chapter 5
Carried Interest
103KA Carried interest

(1)     This section applies where—

(a)     an individual (“A”) performs investment management services directly or indirectly in respect of an investment scheme under arrangements involving at least one partnership, and

(b)     carried interest arises to A under the arrangements.

(2)     If the carried interest arises to A in connection with the disposal of one or more assets of the partnership or partnerships—

(a)     a chargeable gain equal to the amount of the carried interest less any permitted deductions (and no other chargeable gain or loss) is to be treated as accruing to A on the disposal, and

(b)     the chargeable gain is to be treated as accruing to A at the time the carried interest arises.

(3)     If the carried interest arises to A in circumstances other than those specified in subsection (2), a chargeable gain of an amount equal to the amount of the carried interest less any permitted deductions is to be treated as accruing to A at the time the carried interest

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