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Autumn Budget 2024: private equity reforms - a mixed bag

The private equity industry in the UK was on the edge of its seat waiting to see how the new Labour government would act to ‘close the carried interest tax loophole’ as promised in their manifesto. There has been much speculation regarding the likelihood of a new regime based on those found in continental Europe and in particular as to whether the government would adopt a regime like those seen in Spain and Germany (where carry is taxed as income but at a special lower rate) or whether it might instead align with the regimes used in France and Italy. The French regime allows carried interest to be taxed as investment income and gains but only if certain conditions are met such as a requirement to invest a pro rata share of a 1% commitment in the fund and for payment of carry distributions to be...

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