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Section 103KA Carried interestF1F2

(1)

This section applies where—

(a)

an individual performs investment management services directly or indirectly in respect of an investment scheme under any arrangements, and

(b)

the individual is entitled to carried interest under the arrangements.

(2)

Any gain or loss accruing to the individual by virtue of the individual’s entitlement to carried interest is treated as not accruing.

(3)

In this section “arrangements”, “carried interest”, “investment scheme” and “investment management services” have the same meaning as in section 23I of ITTOIA 2005 (see section 23R of and Part 1 of Schedule A1 to that Act).

Annotations

Textual amendments

F1

Pt. 3 Ch. 5 inserted (with effect in accordance with s. 43(2)-(4) of the amending Act) by Finance (No. 2) Act 2015 (c. 33), s. 43(1)

F2

S. 103KA substituted (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. 2(8)

Notes on Part III

Textual amendments

F1

Word in Pt. 3 heading inserted (with effect in accordance with Sch. 22 para. 12 of the amending Act) by Finance Act 2009 (c. 10), Sch. 22 para. 9; S.I. 2010/670, art. 2