[809FZR Direct lending funds: exception]
Income Tax Act 2007 (2007 c 3) | Legislation

[809FZR  Direct lending funds: exception]

[(1)     Section 809FZQ does not apply to carried interest arising from a direct lending fund if—

(a)     the fund is a limited partnership,

(b)     the carried interest is a sum falling within section 809EZD(2) or (3), and

(c)     it is reasonable to suppose that, when investments cease to be made for the purposes of the fund, at least 75% of the direct loans made by the fund (calculated by reference to value advanced) will have been qualifying loans.

(2)

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