Section 23L Carried interest arising where individual deceasedF1

United Kingdom

(1)

This section applies where—

(a)

the individual referred to in section 23I(1)(a)has died, and

(b)

as a result, one or more sums that would have been sums of carried interest arising to the individual from an investment scheme under the arrangements arise instead to another person in a tax year.

(2)

For the purposes of sections 23I and 23K—

(a)

the sums are treated as if they had arisen to the individual in the tax year in which they arose to the other person,

(b)

the other person is treated as carrying on the trade under section 23I for that tax year (instead of the individual), and

(c)

the other person is treated as the person receiving or entitled to the profits of that trade.

Annotations

Textual amendments

F1: 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)