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Why non-dom private equity managers may not be happy with the proposals for carried interest.
KEY POINTS
- Income from carried interest is usually treated as a capital gain.
- UK resident non domiciled fund managers must now pay tax on foreign carried interest gains as they arise.
- Opportunities to restructure the carried interest using corporate vehicles.
- Will the change lead to non-domiciled fund managers leaving the UK?
Hidden among the better publicised tax reforms in the summer Finance Bill 2015 are proposed legislative changes that could affect many foreign domiciled private equity fund managers (FB 2015 clause 40).
Typically private equity fund managers retain a participation in an underlying private equity fund alongside third party investors. This allows the fund managers to share in...
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