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Paragraph 4 Tax distribution treated as “carried interest”F1

(1)

A tax distribution arising to an individual from an investment scheme under arrangements is to be treated as constituting “carried interest”.

(2)

A sum which arises to an individual from an investment scheme under arrangements is a “tax distribution” if—

(a)

under the arrangements the sum is to, or may, arise only if tax (including non-UK tax within the meaning of Part 5 of CTA 2010) becomes payable or is expected to become payable as a result of any individual’s entitlement to carried interest under the arrangements, and

(b)

the sum arising to the individual results in a corresponding deduction in the individual’s entitlement to carried interest.

Annotations

Textual amendments

F1

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