IFM37238 | Charging Provisions: Operation of the charge: Relief for payments to acquire rights to carried interest

Relief for payments to acquire rights to carried interest

TCGA92/S103KA(7)

In circumstances where:

• carried interest arises to an individual;

• they have acquired the right to receive the carried interest from another person; and

• the right was acquired for consideration given in money by or on behalf of the individual, then:

a claim may be made to reduce the amount of chargeable gain arising from the carried interest, by the amount of the consideration given for the acquisition of the right to that carried interest.

Only consideration given in money is permitted as relief under TCGA92/S103KA(7) to reduce the amount of chargeable gain arising.

This relief must be claimed and is not provided automatically when calculating a gain.