{
  "url": "https://openlegislation.uk/income-tax-trading-and-other-income-act-2005/schedule-A1/paragraph-9",
  "json_url": "https://openlegislation.uk/income-tax-trading-and-other-income-act-2005/schedule-A1/paragraph-9.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/9",
  "kind": "paragraph",
  "number": "9",
  "heading": "Deferred sums",
  "text": "(1) But paragraph 8 does not apply in relation to a sum arising to—\n(a) a company connected with A, or\n(b) a person not connected with A,\nfor as long as the sum is a deferred sum in relation to A.\n(2) In this paragraph, “deferred sum”, in relation to A—\n(a) means a sum where the provision of the sum to A or a person connected with A is deferred (whether pending the meeting of any conditions (including conditions which may never be met) or otherwise), and\n(b) includes A's share (as determined on a just and reasonable basis) of any sum the provision of which to A and one or more other persons, taken together, has been deferred (whether pending the meeting of any conditions (including conditions which may never be met) or otherwise).\nIn this sub-paragraph, in a case where the sum referred to in sub-paragraph (1) arises to a company connected with A, the reference to a person connected with A does not include that company.\n(3) Where—\n(a) paragraph 8 has been disapplied in relation to a deferred sum by virtue of sub-paragraph (1), and\n(b) the sum ceases to be a deferred sum in relation to A,\nthe sum is to be regarded as arising to the company or person mentioned in sub-paragraph (1) at the time it ceases to be a deferred sum.\n(4) Section 993 of ITA 2007 (meaning of “connected”) applies for the purposes of this paragraph but as if—\n(a) subsection (4) of that section were omitted, and\n(b) partners in a partnership in which A is also a partner were not “associates” of A for the purposes of sections 450 and 451 of CTA 2010 (“control”).\n(5) A sum which is deferred carried interest within the meaning of section 103KG(3) of TCGA 1992 when this paragraph comes into force is to be treated for the purposes of sub-paragraph (3) as a deferred sum in relation to which paragraph 8 has been disapplied virtue of sub-paragraph (1).",
  "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/9",
    "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."
}