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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: anti-avoidance

Section 23P | Carried interest: anti-avoidance

From legislation.gov.uk

(1)In determining whether section 23I applies in relation to an individual, no regard is to be had to any arrangements the main purpose, or one of the main purposes, of which is to secure that that section does not to any extent apply in relation to—

(a)the individual, or

(b)the individual and one or more other individuals.

(2)In determining whether an individual falls within paragraph (a) of section 23I(1), no regard is to be had to any arrangements the main purpose, or one of the main purposes, of which is to secure that the individual falls within that paragraph.

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