IFM37240 | Charging provisions: Interaction with other taxes

Interaction with other UK taxes

A charge under TCGA92/S103KA does not displace any charge to tax other than CGT that arises by reference to the carried interest. If carried interest represents an amount of income, for example dividends or interest, the fund manager will have two liabilities to tax. Firstly, a liability to income tax on the amount determined in accordance with the appropriate rules (e.g. dividend treatment). Secondly, a chargeable gain calculated in accordance with TCGA92/S103KA(2) or (3) as appropriate. Relief may be claimed for that other tax against the CGT charged under the carried interest rules (IFM37400). This is only applicable to taxes charged under the UK Taxes Acts.