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Legislation
Income Tax (Trading and Other Income) Act 2005

Crossheading Carried interest

  • Section 23I Tax treatment of carried interest
  • Section 23J Election to disapply section 23I
  • Section 23K Location of trade treated as carried on under section 23I etc
  • Section 23L Carried interest arising where individual deceased
  • Section 23M Temporary non-UK residents: tax treatment of accrued carried interest gains
  • Section 23N Permitted deduction etc
  • Section 23P Carried interest: anti-avoidance
  • Section 23Q Carried interest: avoidance of double taxation
  • Section 23R Definitions
  1. Carried interest
  2. Carried interest arising where individual deceased

Section 23L | Carried interest arising where individual deceased

From legislation.gov.uk

(1)This section applies where—

(a)the individual referred to in section 23I(1)(a)has died, and

(b)as a result, one or more sums that would have been sums of carried interest arising to the individual from an investment scheme under the arrangements arise instead to another person in a tax year.

(2)For the purposes of sections 23I and 23K—

(a)the sums are treated as if they had arisen to the individual in the tax year in which they arose to the other person,

(b)the other person is treated as carrying on the trade under section 23I for that tax year (instead of the individual), and

(c)the other person is treated as the person receiving or entitled to the profits of that trade.

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