IFM37234 | Charging Provisions: Operation of the charge: Other circumstances

Other circumstances

TCGA92/S103KA(3)

The carried interest rules also apply where carried interest arises to an individual where there has been no underlying disposal of partnership assets, for example a sum of dividend income being allocated as carried interest. Where this occurs, the normal taxation rules which apply to that sum operate in parallel and credit will be given where appropriate for the CGT on the carried interest arising.