Part 4: Income tax, corporation tax and capital gains tax Section 44: Disguised investment management fees Summary Details of the section
Subsection (1) introduces new subsection (2A) into section 809EZB of ITA 2007.
	Section809EZB(2A) explains what is meant by the phrase "reasonably comparable" in section 809EZB subsection (2)(b). That subsection requires that the return on an investment made by a fund manager be reasonably comparable to the return on the same kind of investments made by external investors. New section 103KA(8) TCGA 1992 (see above) uses the conditions in section 809EZB(2) ITA to define a "co-investment".
	Subsection (2) amends section 809EZG of ITA 2007 (avoidance of double taxation) so that its scope is the same as that of section 103KE of TCGA 1992.
	Subsection (3) specifies that the changes made by subsections (1) and (2) apply in relation to any management fees arising on or after 8 July 2015.
	Subsection (4) ensures that, for the purposes of the commencement provision in subsection (3), "arise" (and, by extension, "arising") has the same meaning as in the disguised management fee rules in Chapter 5E of Part 13 of ITA 2007.