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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. Relief for external investors on disposal of partnership asset

Section 103KF | Relief for external investors on disposal of partnership asset F1

From legislation.gov.uk

(1)If—F1

(a)a chargeable gain accrues to an external investor in an investment scheme on the disposal of one or more partnership assets, andF1

(b)the external investor makes a claim for relief under this section,F1

then subsection (2) applies in relation to the disposal.

(2)The amount of the chargeable gain is to be reduced by an amount equal to—F1

Formula

I−C

where—

I is an amount equal to such part of the sum invested in the fund by the external investor which on a just and reasonable basis is referable to the asset or assets disposed of, and

C is the amount deducted under section 38(1)(a) in respect of consideration given wholly and exclusively for the acquisition of the asset or assets.

(3)In this section, “external investor” and “investment scheme” have the same meaning as in section 23I of ITTOIA 2005 (see section 23R of that Act).F1F2

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. 103KF(3) inserted (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(10)

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