Technical 19 October 2023 Issue 5 Patrick Harney TEP

Carry on, regardless

Patrick Harney and Christopher Eames outline tax- and estate-planning considerations for carried interest in the UK

Key points

What is the issue?

Carried interest is excluded from the normal protected settlement regime that applies to settlors who are not domiciled in the UK as a matter of common law.

What does it mean for me?

Those advising non-domiciled private equity executives resident in the UK are more constrained in the planning they can recommend, when compared to traditional techniques used for non-UK domiciliaries.

What can I take away? 

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