Part 13Tax avoidance
F1CHAPTER 5FIncome-based carried interest
Annotations:
Amendments (Textual)
Average holding period: disposals
809FZEPart disposals
1
Where there is a disposal of part of an investment, the part disposed of and the part not disposed of are to be treated as two separate investments which were made at the same time.
2
The value of each of those two separate investments is the appropriate proportion of the value first invested in the whole investment.
3
The appropriate proportion is the proportion of the value of the part in question to the value of the whole investment at the time of the disposal.
4
The disposal of part of an asset includes the disposal of an interest in or right over the asset (and “part disposed of” is to be construed accordingly).
Pt. 13 Ch. 5F inserted (with effect in accordance with s. 37(4) of the amending Act) by Finance Act 2016 (c. 24), s. 37(2)