Skip to content
Solved
SearchBrowse
Sign in

Contents

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. Permitted deduction etc

Section 23N | Permitted deduction etc

From legislation.gov.uk

(1)For the purpose of section 23I the amount of any “permitted deduction” for a tax year is—

(a)the amount of any consideration given by or on behalf of the individual wholly and exclusively for the entitlement to carried interest under the arrangements referred to in section 23I(1)(a), minus

(b)the amount of any such consideration deducted in calculating the profits of a trade that the individual is treated as carrying on under section 23I for an earlier tax year by virtue of those arrangements.

(2)In subsection (1), “consideration” means consideration in money or money’s worth but does not include the performance of any investment management services directly or indirectly in respect of an investment scheme.

(3)For the purposes of this Act no other deduction may be made from the amount treated as the profits of the trade under section 23I.

PreviousNext
PrivacyTerms