Section 103KFE: Anti-avoidance

Taxation of Chargeable Gains Act 1992 · 1992 c. 12View on legislation.gov.uk

Part III: Individuals, partnerships, trusts and collective investment schemes etc — Chapter 5: Carried interest

This section applies where an election was made by an individual under section 103KFA and the main purpose, or one of the main purposes, of making the election is to cause a loss to be treated as accruing to the individual under subsection (3) of section 103KFD.

Any such loss that would (in the absence of this section) accrue to the individual under that subsection is to be counteracted by the making of such adjustments as are just and reasonable.

Any adjustments required to be made under this section (whether or not by an officer of Revenue and Customs) may be made by way of—

an assessment,
the modification of an assessment, or
amendment or disallowance of a claim, or otherwise.

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Reuse reviewed 21 August 2026 under Open Government Licence v3.0.