Introduction Summary
1.This section applies to certain fees or other sums paid to investment managers, and provides that in some circumstances these sums will be charged to income tax. It applies to sums paid through structures involving partnerships, unless they are already charged to income tax as employment income or brought into account in calculating profits. Carried interest is excluded from the charge. The section comes into effect on 6 April 2015, in respect of disguised fees arising on or after that date, whenever the arrangements were entered into.