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Contents

Official guidance
Investment Funds Manual

IFM37230 · Charging Provisions: Operation of the charge

  • IFM37231 · Overview
  • IFM37232 · Disposals
  • IFM37234 · Other circumstances
  • IFM37236 · Permitted deductions
  • IFM37238 · Relief for payments to acquire rights to carried interest
  1. Charging Provisions: Operation of the charge: Contents
  2. Charging Provisions: Operation of the charge: Overview

IFM37231 | Charging Provisions: Operation of the charge: Overview

From HM Revenue & Customs · Investment Funds Manual

TCGA92/S103KA

The amount of carried interest arising (IFM37261) will be the amount of the gain, subject only to deductions for money actually paid by the individual for the right to carried interest, and for amounts charged to income tax in respect of the acquisition of those rights.

Carried interest can arise under two different provisions. Broadly, the first caters for situations where the carried interest arises in respect of a disposal of assets of a partnership (TCGA92/S103KA(2)) (IFM37232) and the second applies where carried interest arises in all other circumstances (TCGA92/S103KA(3)) (IFM37234).

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