Taxation of Chargeable Gains Act 1992 section 103KFB

Election in relation to scheme to apply to associated schemes

Section 103KFB provides that where an election has been made to treat carried interest gains as arising in line with scheme profits for a particular investment scheme, that election automatically extends to any associated investment schemes.

• When an election under section 103KFA is made for an investment scheme, it automatically covers any associated investment schemes as well.
• The extension to associated schemes applies regardless of whether those other schemes independently met the conditions for such an election at the time it was made.
• This prevents fund managers from selectively applying the election to some schemes within a group while excluding others that are linked.
• The meaning of "associated" in relation to investment schemes is determined by reference to the definition in section 809FZZ of the Income Tax Act 2007.