{
  "url": "https://openlegislation.uk/income-tax-trading-and-other-income-act-2005/section-23J",
  "json_url": "https://openlegislation.uk/income-tax-trading-and-other-income-act-2005/section-23J.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": "section/23J",
  "kind": "section",
  "number": "23J",
  "heading": "Election to disapply section 23I",
  "text": "(1) An individual who performs investment management services directly or indirectly in respect of an investment scheme under arrangements mentioned in section 23I(1)(a) may make an election under this section.\n(2) Where an election made under this section has effect for a tax year, the election applies in relation to a sum of carried interest arising to the individual under the arrangements in the tax year to the extent that the carried interest would, ignoring this group of sections, be brought into account in calculating the profits of a trade of the individual for the purposes of income tax for any tax year.\n(3) An election made under this section—\n(a) must be made by notice given to an officer of Revenue and Customs, and\n(b) may not be revoked.\n(4) A notice making an election—\n(a) must state the tax year for which it is to have effect, and\n(b) may not be given after 31 January following the end of that tax year.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Ss. 23I-23R and cross-heading 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(2)(6)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2005/5/section/23J",
    "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."
}