Introduction Summary
1.This section and Schedule introduces a mechanism for members of alternative investment fund managers (AIFM) partnerships (including their delegates and sub-delegates) to allocate certain ‘restricted’ profits to the partnership.
2.These are profits that those members cannot immediately access because of requirements under the Alternative Investment Fund Managers Directive (AIFMD) (2011/61/EU) to defer remuneration of ‘key staff’.
3.The legislation imposes a charge to tax on these profits at the additional rate of tax  (45 per cent) to be paid by the AIFM partnership.
4.It also sets out the capital gains treatment where the partner’s remuneration is in the form of instruments in the fund under management.