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Schedule 22 & the Private Equity Arena

 
Fiona Talbot Senior Tax Manager of the Entrepreneurial Companies and Private Client team at PricewaterhouseCoopers looks at the impact of Schedule 22 on the Private Equity Industry
 
The introduction of Finance Act 2003 Schedule 22 had wide-ranging repercussions for the taxation of securities held by employees. It was not clear however whether and to what extent that new legislation would apply to the private equity industry.
 
This article provides an overview of the traditional private equity structures for carried interest and provides guidance to their tax treatment in the wake of Schedule 22 and the Memorandum of Understanding.
Introduction
 
A limited partnership is the traditional private equity fund-raising and investment...

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