Taxation of Chargeable Gains Act 1992 section 103KF

Relief for external investors on disposal of partnership asset

Section 103KF provides a relief that reduces the chargeable gain arising to an external investor in an investment scheme when one or more partnership assets are disposed of, by giving credit for the investor's own capital contribution to the fund.

• An external investor in an investment scheme who realises a chargeable gain on the disposal of partnership assets may claim relief under this section to reduce that gain.
• The reduction equals the investor's capital invested in the fund attributable to the disposed assets (I), minus the acquisition cost already deducted in the gain computation (C).
• The attribution of the investor's capital to the specific assets disposed of must be done on a just and reasonable basis.
• This relief applies to carried interest arising on or after 8 July 2015, unless the carried interest relates to disposals of partnership assets before that date.