Taxation of Chargeable Gains Act 1992 section 103KC

Carried interest: foreign chargeable gains

Section 103KC determines how chargeable gains arising from carried interest on non-UK assets are treated for individuals who are not UK-domiciled, by linking the taxable portion to the location where the relevant services were performed.

• Where section 103KA applies and a gain arises from carried interest on an asset situated outside the UK, only part of that gain may be chargeable to UK tax.
• The chargeable portion is limited to the extent that the individual performed the relevant investment management services outside the United Kingdom.
• This provision is relevant to non-UK domiciled fund managers who may benefit from the remittance basis, ensuring that only the foreign-service element is treated as a foreign gain.
• The rules apply to carried interest arising on or after 8 July 2015, unless the carried interest relates to a disposal of partnership assets that took place before that date.