Private equity funds

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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 would introduce a revised tax regime for carried interest from 6 April 2026 that would sit within the income tax framework, subject to special rules to take account of the unique characteristics of the reward. A consultation on potential new qualifying conditions for access into the new regime followed, with a government response to this being issued in June 2025. Draft legislation for the new tax regime for carried interest was published on 21 July 2025, for inclusion in Finance Bill 2026. The new rules will have effect for carried interest arising on or after 6 April 2026. All this was confirmed at the Budget on 26 November 2025, where it was also noted that some changes had been made to the draft legislation to reflect stakeholder feedback. Pending the coming into force of the new regime, the capital gains tax rates applicable to carried interest were increased to 32% with

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Latest Tax News

Tax—publication of Finance Bill 2026

Tax analysis: The government published Finance Bill 2026, also known as Finance (No 2) Bill 2024–26 and Finance Bill 2025–26 (FB 2026), on 4 December 2025.

Tax weekly highlights—4 December 2025

This week's edition of Tax weekly highlights includes: (1) publication of Finance Bill 2026, (2) publication of the National Insurance Contributions (Employer Pensions Contributions) Bill, (3) the delayed publication of the Overview of Tax Legislation and Rates (OOTLAR) setting out details of tax measures announced at Budget 2025 and of previously announced measures that are included in FB 2026, and (4) a reminder of our full Budget 2025 coverage and upcoming related news.

Private Client—publication of Finance Bill 2026

Private Client analysis: Finance (No 2) Bill 2024–26 (F(No 2)B 2024–26), also known as Finance Bill 2026 and to be enacted as Finance Act 2026, was published on 4 December 2025.

FTT stays the taxpayer’s appeal on exempt supply of land for service charges, provisionally siding with HMRC’s arguments (Places for People Homes Ltd v HMRC)

Tax analysis: In Places for People Homes Ltd v HMRC the First-tier Tax Tribunal (FTT) found in favour of HMRC that certain supplies made by maintenance trust companies were taxable, rather than exempt supplies under Schedule 9, Group 1 of the Value Added Tax Act 1994 (VATA 1994) (exemption for supplies relating to land).

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