Damien Crossley and Bezhan Salehy (Macfarlanes) examine the Government’s latest policy paper.
Background
At the Autumn Budget 2024 the Government announced that the carried interest tax regime would be reformed so that from 6 April 2026 carried interest receipts will be exclusively taxed within the income tax and NICs regime as receipts of a deemed trade carried on by the relevant executive. Importantly however qualifying carried interest receipts will be subject to a multiplier of 72.5% so that additional rate taxpayers will pay an overall 34.1% effective rate of income tax and NICs. Qualifying carry will be amounts that satisfy the current definition of carried interest and which do not fall foul of the IBCI rules that from 6 April 2026 will need to be navigated in...
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Damien Crossley and Bezhan Salehy (Macfarlanes) examine the Government’s latest policy paper.
Background
At the Autumn Budget 2024 the Government announced that the carried interest tax regime would be reformed so that from 6 April 2026 carried interest receipts will be exclusively taxed within the income tax and NICs regime as receipts of a deemed trade carried on by the relevant executive. Importantly however qualifying carried interest receipts will be subject to a multiplier of 72.5% so that additional rate taxpayers will pay an overall 34.1% effective rate of income tax and NICs. Qualifying carry will be amounts that satisfy the current definition of carried interest and which do not fall foul of the IBCI rules that from 6 April 2026 will need to be navigated in...
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