New rules in this year’s Finance Act are intended to ensure that sums which arise to investment managers for their services from the funds that they manage are charged to income tax. Although the rules are intended to exclude ‘carried interest’ and returns from investments in funds, the current drafting of these exclusions (which may change during the consultation process) is very narrow, meaning that many such arrangements would be caught. Fund managers will need to consider how the rules might apply to their arrangements and consider taking up the welcome opportunity to engage with HMRC on the current drafting before the 4 February deadline.
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