# Income Tax (Trading and Other Income) Act 2005, Section 23M: Temporary non-UK residents: tax treatment of accrued carried interest gains

Extent: E+W+S+N.I.

(1) This section applies where, on the disposal of an asset by an individual who was temporarily non-resident in tax year 2025-26 or earlier, a gain accrued to the individual in the temporary period of non-residence under section 103KA(2) or (3) of TCGA 1992 (as it then had effect).
(2) For income tax purposes—
(a) the individual is treated as carrying on a trade for the period of return,
(b) the amount to be treated as the profits of the trade for the period of return is 72.5% of the amount of the gain which accrued to the individual in the temporary period of non-residence, and
(c) the individual is treated as the person receiving or entitled to those profits.
(3) For the purposes of this section, “the period of return”, “temporarily non-resident” and “the temporary period of non-residence” have the meanings given by Part 4 of Schedule 45 to FA 2013 (statutory residence test: anti-avoidance).

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Source: https://www.legislation.gov.uk/ukpga/2005/5/section/23M (the official version)
Page: https://openlegislation.uk/income-tax-trading-and-other-income-act-2005/section-23M
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.