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Legislation
Income Tax Act 2007

CHAPTER 5E Disguised investment management fees

  • Section 809EZA Disguised investment management fees: charge to income tax
  • Section 809EZB Meaning of “management fee” in section 809EZA
  • Section 809EZC Meaning of “carried interest” in section 809EZB
  • Section 809EZD Sums treated as “carried interest” for purposes of section 809EZB
  • Section 809EZDA Sums arising to connected persons other than companies
  • Section 809EZDB Sums arising to connected company or unconnected person
  • Section 809EZE Interpretation of Chapter
  • Section 809EZF Disguised investment management fees: anti-avoidance
  • Section 809EZG Disguised investment management fees: avoidance of double taxation
  • Section 809EZH Powers to amend Chapter
  1. Chapter 5E
  2. Sums arising to connected persons other than companies

Section 809EZDA | Sums arising to connected persons other than companies

From legislation.gov.uk

(1)This section applies in relation to an individual (“A”) if—

(a)a sum arises to a person (“B”) who is connected with A,

(b)B is not a company,

(c)Repealed

(d)Repealed

(e)the sum does not arise to A apart from this section.

(2)The sum referred to in subsection (1)(a) arises to A for the purposes of this Chapter.

(3)Where a sum arises to A by virtue of this section, it arises to A at the time the sum referred to in subsection (1)(a) arises to B.

(4)Section 993 (meaning of “connected”) applies for the purposes of this section, but as if—

(a)subsection (4) of that section were omitted, and

(b)partners in a partnership in which A is also a partner were not “associates” of A for the purposes of sections 450 and 451 of CTA 2010 (“control”).

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