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FA 2015: Disguised investment management fee rules

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ITA 2007 Part 13 Chapter 5E, brought into law by FA 2015 s 21, introduces the new disguised investment management fee (or ‘disguised fee’) rules for relevant sums arising on or after 6 April 2015. These rules were the subject of draft legislation published in December 2014 and consultation with HMRC between then and publication of the Finance Bill on 24 March 2015. Where they apply, the rules will result in sums arising to investment managers which are disguised fees being taxed as trading income at marginal ordinary income tax rules with self-employed national insurance contributions. The approach to the new rules is similar to that taken in the draft rules, but the detail varies in some important and improved ways.

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