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Rules on carried interest gains applied to fund management fees

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

KEY POINTS

  • 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...

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