Section 23P Carried interest: anti-avoidanceF1
United Kingdom
In determining whether section 23I applies in relation to an individual, no regard is to be had to any arrangements the main purpose, or one of the main purposes, of which is to secure that that section does not to any extent apply in relation to—
the individual, or
the individual and one or more other individuals.
In determining whether an individual falls within paragraph (a) of section 23I(1), no regard is to be had to any arrangements the main purpose, or one of the main purposes, of which is to secure that the individual falls within that paragraph.
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)