{
  "url": "https://openlegislation.uk/income-tax-trading-and-other-income-act-2005/schedule-A1/paragraph-3",
  "json_url": "https://openlegislation.uk/income-tax-trading-and-other-income-act-2005/schedule-A1/paragraph-3.json",
  "legislation": "ukpga/2005/5",
  "legislation_title": "Income Tax (Trading and Other Income) Act 2005",
  "legislation_url": "https://openlegislation.uk/income-tax-trading-and-other-income-act-2005",
  "path": "schedule/A1/paragraph/3",
  "kind": "paragraph",
  "number": "3",
  "heading": "Consideration for right to sum of carried interest treated as “carried interest”",
  "text": "(1) Sub-paragraph (2) applies to consideration that is received or receivable—\n(a) by an individual for the disposal, variation, loss or cancellation of the individual’s right to a sum arising from an investment scheme under arrangements by way of profit-related return, or\n(b) by a person who is a relevant person in relation to the individual, for the disposal, variation, loss or cancellation of the relevant person’s right to a sum arising from an investment scheme under arrangements by way of profit-related return.\n(2) The consideration, to the extent that it is not a disguised fee arising to the individual for the purposes of section 809EZA of ITA 2007—\n(a) is to be treated as a sum which arises to the individual from the scheme under the arrangements by way of profit-related return at the time of the disposal, variation, loss or cancellation, and\n(b) accordingly, is to be treated as constituting “carried interest”.\n(3) For the purposes of sub-paragraph (1), a person is a “relevant person” in relation to an individual if carried interest arising to that person would be treated as arising to the individual for the purposes of section 23I (see paragraph 7 and paragraph 8 of this Schedule).",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Sch. A1 inserted (for the tax year 2026-27 and subsequent tax years (but in relation to investment management services whenever performed)) by Finance Act 2026 (c. 11), s. 58(6), Sch. 11 para. 1"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2005/5/schedule/A1/paragraph/3",
    "retrieved_at": "2026-10-29T09:16:32.370392+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}