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Legislation
Taxation of Chargeable Gains Act 1992

Chapter 5 Carried interest

  • Section 103KA Carried interest
  • Section 103KB Carried interest: consideration on disposal etc of right
  • Section 103KC Carried interest: foreign chargeable gains
  • Section 103KD Carried interest: anti-avoidance
  • Section 103KE Carried interest: avoidance of double taxation
  • Section 103KF Relief for external investors on disposal of partnership asset
  • Section 103KFA Election for carried interest gains to be chargeable as scheme profits arise
  • Section 103KFB Election in relation to scheme to apply to associated schemes
  • Section 103KFC Interaction with other charges
  • Section 103KFD Deemed accrual of loss where carried interest never arises
  • Section 103KFE Anti-avoidance
  • Section 103KG Meaning of “arise” in Chapter 5
  • Section 103KH Interpretation of Chapter 5
  1. Chapter 5 · Carried interest
  2. Carried interest

Section 103KA | Carried interest F1F2

From legislation.gov.uk

(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).

Notes

  1. 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)

  2. 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)

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