PART 4Capital gains tax

Employee shareholder shares

89Employee shareholder shares: disguised fees and carried interest

1

In section 236B of TCGA 1992 (exemption for employee shareholder shares), after subsection (2) insert—

2A

Subsection (1) does not apply in relation to a gain accruing on a disposal where the proceeds of the disposal, in relation to any individual, constitute—

a

a disguised fee for the purposes of Chapter 5E of Part 13 of ITA 2007 (see section 809EZA(3) of that Act), or

b

carried interest within the meaning given by section 809EZC of that Act.

2

The amendment made by this section has effect in relation to gains accruing on or after 6 April 2016.