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Carried interest: the new landscape

Laura Charkin and Stephen Pevsner (King & Wood Mallesons) look back on a turbulent year for fund managers and consider the proposed new ‘income-based carried interest’ tax rules.

Ever since the first major shock waves created by the announcement of new tax rules in relation to sums paid to fund managers at the end of 2014 the so-called ‘disguised investment management fee’ (DIMF) rules there has been little respite from the ripple effect of further changes for those working in this area. The latest development comes in the form of draft legislation for new ‘income-based carried interest’ rules which are hoped to be the final addition to the new and comprehensive tax system in this area. With a complex new landscape to navigate this article considers the detail of these draft rules in particular and looks at the ‘lie of the land’ overall under...

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