Contribution by Gabriele Schiavone, SGS Partners, London and Abu Dhabi; and Matteo Colafrancesco, SGS Partners, Lugano and London.
The new framework requires a review of existing carry structures, because the absence of grandfathering and its taking effect from 6 April 2026 make even arrangements already in place relevant for those payments arising from that date. In parallel, asset management groups must implement robust procedures to track AWP, UK work days, the residence position of individual beneficiaries, and cash-flow analysis. From 6 April 2026 the United Kingdom radically changed the carried interest regime, which has been brought within Income Tax — albeit under specific rules — but many points remain to be clarified, especially in the case of individuals leaving the country, those who carry out certain activities across multiple jurisdictions, and new residents.
Read Full Article Here
Read English version here.
