Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Rules on carried interest gains applied to fund management fees

26 November 2019 / Marie Barber
Issue: 4722 / Categories: Comment & Analysis
© iStockphoto/belterz
Changing outlook


  • Changes to carried interest introduced in April 2015 applied to management fees arising from collective investment schemes.
  • Later amendments in 2015 ensure carried interest gains were taxed at a minimum of 28% and removed base cost shift.
  • Under the 2016 income-based carried interest rules only long-term gains can be taxed as capital gains.
  • Carried interest gains can benefit from the remittance basis if they arise from demonstrably offshore activities.

Not all Taxation readers will act for private equity and hedge funds and their managers and partners but for those who do the rules on carried interest will be relevant. In brief carried interest is the technical term given to the share of profits earned by an investment team when an investment made within a private equity fund is disposed of generating a gain for the investors. Carried interest seeks to align the interests of the investment...

If you or your firm subscribes to, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.

back to top icon