Disguised investment management fee (DIMF) rules

Copyright © 2025 LexisNexis
Produced in partnership with Emily Clark of Travers Smith
Practice notes

Disguised investment management fee (DIMF) rules

Copyright © 2025 LexisNexis

Produced in partnership with Emily Clark of Travers Smith

Practice notes
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FORTHCOMING CHANGE relating to the tax treatment of carried interest: Following a call for evidence on the tax treatment of carried interest that ran over summer 2024, at Autumn Budget 2024 the government announced that it will introduce a revised tax regime for carried interest, from 6 April 2026, that will sit within the income tax framework, subject to special rules to take account of the unique characteristics of the reward. Draft legislation for the new tax regime for carried interest can be expected during 2025. In the meantime, the capital gains tax rates currently applicable to carried interest will be increased to 32% from 6 April 2025. Legislation for that measure will be included in the Autumn Finance Bill 2024. For more on the government announcement on carried interest tax reform, including some commentary from legal experts in the field, see News Analyses: Autumn Budget 2024—Tax analysis—Private equity and venture capital and Autumn Budget 2024—carried interest taxation reform.

FORTHCOMING CHANGE relating to abolition of non-dom regime and introduction of residence-based IHT

Emily Clark
Emily Clark

Partner, 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.

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Jurisdiction(s):
United Kingdom
Related legal acts:
Key definition:
Investment definition
What does Investment mean?

An investment will typically mean any type of property or interest held within the territory of the host state. This will often extend far beyond 'obvious' property, such as real estate or shares in a local company, to (depending upon the circumstances) other interests such as rights under a contract, intellectual property rights and private loans. As with the concept of 'investor,' in the modern commercial world what does and does not qualify as investment can be a complex question. The definition of 'investment' will vary between BITs.

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