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After a long period of speculation including by two of the authors of this article Ben Jones and Ben Shem-Tov in ‘Looking to make a change’ (Taxation 29 June 2023) the UK chancellor Rachel Reeves and the Treasury (HMT) have announced a number of new measures which herald a fundamental reform of how carried interest will be taxed in the UK.
In this article we provide a refresher on what carried interest is and the preferential tax treatment it has typically attracted for those in the private capital sector take a brief glance at the road leading to change and then delve into the announced changes and HMT’s further consultation.
What is carried interest?
A typical private fund structure will utilise a limited partnership as the main fund vehicle with investors investing into the fund as limited partners their share...
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