{
  "url": "https://openlegislation.uk/income-tax-trading-and-other-income-act-2005/schedule-A1/paragraph-4",
  "json_url": "https://openlegislation.uk/income-tax-trading-and-other-income-act-2005/schedule-A1/paragraph-4.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/4",
  "kind": "paragraph",
  "number": "4",
  "heading": "Tax distribution treated as “carried interest”",
  "text": "(1) A tax distribution arising to an individual from an investment scheme under arrangements is to be treated as constituting “carried interest”.\n(2) A sum which arises to an individual from an investment scheme under arrangements is a “tax distribution” if—\n(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\n(b) the sum arising to the individual results in a corresponding deduction in the individual’s entitlement to carried interest.",
  "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/4",
    "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."
}