Income Tax (Trading and Other Income) Act 2005 section 863H

Election for special provision for alternative investment fund managers to apply

Section 863H allows an alternative investment fund manager (AIFM) partnership to elect into special profit allocation rules under section 863I, and defines the key terms "AIFM firm" and "AIFM trade".

• An AIFM firm can elect for the special profit allocation rules in section 863I to apply to its AIFM trade
• The election must be made within 6 months after the end of the first period of account for which it is to take effect
• An AIFM firm is a partnership whose regular business is managing alternative investment funds, or which carries out management functions as a delegate or sub-delegate of such a manager
• An AIFM trade is any trade of the AIFM firm that involves those fund management activities