45 Carried interest and disguised investment management fees: “arise”
Finance (No 2) Act 2015 (2015 c 33) | Legislation

45  Carried interest and disguised investment management fees: “arise”

(1)     In ITA 2007, after section 809EZD insert—

“809EZDA Sums arising to connected persons other than companies

(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)     income tax is not charged on B in respect of the sum by virtue of this Chapter,

(d)     capital gains tax is not charged on B in respect of the sum by virtue of Chapter 5 of Part 3 of TCGA 1992, and

(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”

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