Background Note
37.This section has been introduced to ensure that fees or other sums for investment management paid to managers of funds are charged to income tax. Structures have increasingly been used by private equity firms in which annual fees are paid as priority partnership shares to avoid an income tax charge on the fees.
38.Sums received by managers which represent returns linked to investment performance (carried interest) or investment by managers (co-investment) will not be affected by this measure.
