Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Investment definition

What does Investment mean? In practice, investment describes an asset or bundle of rights committed in a host state with the aim of generating a return. In investor-state work, the operative definition is treaty-specific: most bilateral investment treaties (BITs) and the Energy Charter Treaty use broad, asset-based lists covering, where applicable, tangible and intangible property located in the territory, shareholdings and other equity interests, contractual rights (including concessions), intellectual property, and loans or claims to money, subject to stated carve-outs. The ICSID Convention does not define investment; tribunals assess jurisdiction by the treaty text and case law, commonly considering a contribution of resources,...

UK DIMF rules: taxation of management fees, deemed-arising and enjoyment conditions, carried interest and co-investment exclusions, IBCI interaction, anti-avoidance and double taxation relief

Published by a LexisNexis Tax expert

Practice notes

FORTHCOMING CHANGE relating to the tax treatment of carried interest:

After a call for evidence on the taxation of carried interest that ran through summer 2024, the Autumn Budget 2024 set out plans to introduce a revamped carried interest regime from 6 April 2026. This will sit within the income tax system, with tailored rules to reflect the distinctive features of the reward. The intention is to recognise the particular nature of such rewards within taxation. A consultation then examined potential new qualifying criteria for access to the regime, and the government issued its response in June 2025. Draft legislation for the carried interest regime was published on 21 July 2025, intended for inclusion in Finance Bill 2026. The provisions will apply to carried interest arising on or after 6 April 2026. All of this was confirmed at the 26 November 2025 Budget, which also noted that certain changes had been made to the draft legislation to take account of stakeholder feedback. In the interim, and until the new regime is in force, the capital gains tax rate applicable to carried interest was increased to 32% with effect from 6 April 2025. For more on this carried interest tax reform,...

To view the latest version of this document and thousands of others like it, sign-in with LexisNexis or register for a free trial.

Emily Clark

Travers Smith

Emily trained at Travers Smith and is a partner in the tax group. She specialises in the taxation of investment funds acting for private equity houses, hedge funds and real estate funds.She advises on fund formation and on tax-efficient structures for fund managers, carried interest and LLP conversions. She has particular expertise in tax structuring for non-domiciled investors and fund managers.Emily also has extensive experience of group restructuring, international tax, joint ventures and real Emily is a member of the British Property Federation´s tax committee....

Web page updated on 21/05/2026

Popular documents

Using the Judicial College Guidelines to assess general damages in personal injury claims

When evaluating a general damages claim, the practitioner ought initially to refer to the Judicial College Guidelines (JCG)...

Tomlin orders in England and Wales: CPR guidance on drafting, confidentiality, approval, variation, enforcement, limitation, CCA issues, court-specific requirements, sample wording and precedents

This Practice Note This Practice Note reviews mechanisms used in settling litigation. A Tomlin order consists of a consent order paired with a schedule. It operates to stay proceedings on terms that have been agreed. The provisions contained in the schedule may remain confidential. This Practice Note describes the scope of confidentiality attaching to the schedule and sets out how it differs from a standard consent order. Sample wording for a Tomlin order is included, alongside links to precedents, as well as guidance on court approval. It also addresses varying, setting aside and enforcing a Tomlin order, including the considerations the court will take into account when handling applications for each. Further guidance is provided on interpreting and applying the relevant provisions of the CPR; however, some courts and divisions impose very specific requirements for both drafting and approval, and for approaching the schedule and confidentiality issues. Accordingly, you must consider the particular rules and court guide provisions in the forum where your claim is proceeding when drawing up the Tomlin order...

Precedent: Deed of Surrender of Lease with Optional Premium, Settlement and Release, Landlord, Mortgagee and Guarantor Consents, Reimbursement and HM Land Registry Provisions (England and Wales)

Date [ date ] Parties [ name of Landlord ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Landlord) [ name of Tenant ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Tenant) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Guarantor) ] [ [ name of Mortgagee ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Mortgagee) ] Definitions Within this Deed, the terms below shall be interpreted as follows: [ Annual Rent • the annual sum reserved under the Lease; ] [ Insurance Rent • the Tenant’s share of the Landlord’s costs of insuring the Property (as set out in the Lease); ] Lease • the lease of the Property dated [ date ], entered into between (1) [ the Landlord OR [ name ...

Precedent Statutory Declaration: Standard Wording under the Statutory Declarations Act 1835

I, [ name ], of [ address ], solemnly and sincerely state that: [ Matters to be verified, set out in numbered paragraphs ] I make this solemn statement in good conscience, believing it to be true, and pursuant to the provisions of the Statutory Declarations Act 1835. DECLARED at [ details ] this [ day ] day of [ month and year ] Before me ................................................................................ [ signature of the person before whom the declaration is made ] A [ commissioner for oaths OR [ solicitor OR [ insert other qualification ] ] authorised to administer oaths ]...