Following HM Treasury launching a “call for evidence” on reforming the taxation of carried interest a few weeks ago, we published a document outlining the current UK regime and international comparators, and examining the possible options for reform.

While the call for evidence is focused on the design of the future UK carried interest rules, we believe the interaction of those rules with the taxation of inpatriates is equally important. In this supplementary document we explain how the UK currently receives an out-sized share of total European carried receipts. It also outlines that, to maintain that preeminent position in the future, it is critical that the UK is able to retain private capital executives that are currently inpatriates and continue to attract the next generation of inpatriate talent.

Please get in touch if you would like to speak with us on this topic.