The tax environment facing UK portfolio managers and fund managers has been transformed by a sequence of legislative changes between 2024 and 2026. Understanding these changes and acting on them with specialist advice, is no longer optional for those with material investment management income.
Carried Interest Reform - From CGT to Trading Profit (April 2026)
This is the most consequential tax change for UK fund managers in decades.
From 6 April 2026, carried interest is taxed as trading profits under the Income Tax framework, at rates of up to 45% plus Class 4 NICs, with special computational rules applying a 72.5% multiplier to qualifying carried interest. This results in an effective tax rate of 34.075% for additional rate taxpayers including NIC.
The transition carries significant practical implications beyond the headline rate change:
Payments on account: Under the new rules, tax and NICs on carried interest will be relevant for calculating a person's payments on account for the following year, creating significant cash flow implications for carried interest holders. Most private equity professionals were not previously subject to payments on account on their carry; this has changed entirely.
Qualifying carried interest conditions: For carried interest to be qualifying and therefore for the 72.5% multiplier to apply, it must meet conditions including a weighted average holding period of the fund's investments of at least 40 months, with partial relief for periods of at least 36 months.
Making Tax Digital implications: As carried interest is now treated as trading profit, it falls within the MTD for Income Tax regime in the same way as any other trade. This means quarterly digital submissions to HMRC from April 2026 for those who meet the income threshold.
Interim CGT rate: From 6 April 2025 to 5 April 2026, carried interest is taxed at 32% under the CGT regime. Timing decisions around when carried interest crystallises in this transitional period require careful, specialist analysis.
For any fund manager with carried interest, a comprehensive review of your position under the new regime is not a planning nicety but it is an urgent financial necessity.
Rates Increased Across the Board (Capital Gains Tax)
From 30 October 2024, the lower rate of CGT increased from 10% to 18% and the higher rate from 20% to 24%. For portfolio managers and investment professionals with personal investment portfolios, co-investment positions, and direct asset holdings, these higher rates materially alter the after-tax return on disposals and the timing decisions around realising gains.
The annual CGT exemption is now £3,000, reduced from £12,300 just two years earlier. The combination of higher rates and a near-eliminated exemption means that personal investment portfolio management now demands an actively tax-aware approach that many individual investors and their accountants are not applying.
The Personal Allowance Trap for High-Earning Investment Professionals
For investment professionals earning above £100,000, the personal allowance tapers by £1 for every £2 of income above that level; disappearing entirely at £125,140. This creates an effective marginal tax rate of 60% in this income band. For those with substantial management fee income, salary, and bonus, this is one of the highest-value and most accessible areas of legitimate tax planning and one of the most frequently neglected by advisers who do not specialise in high-income professionals.
Making Tax Digital (April 2026)
Self-employed portfolio managers and investment professionals with gross income above £50,000 must comply with Making Tax Digital for Income Tax from April 2026, submitting quarterly digital updates to HMRC. As noted above, the reclassification of carried interest as trading profit also brings carried interest holders within the MTD framework. The threshold reduces to £30,000 in 2027 and £20,000 in 2028. Non-compliance carries automatic financial penalties per missed submission.
Impact on Internationally Mobile Fund Managers (Non-Dom Reform)
From April 2025, the UK abolished the remittance basis of taxation, replacing it with the four-year Foreign Income and Gains (FIG) regime for qualifying new arrivals. For internationally mobile fund managers particularly those who have previously sheltered offshore fund income from UK tax under the remittance basis the implications are far-reaching. The Temporary Repatriation Facility allows previously sheltered income to be remitted at 12% in 2025-26 and 2026-27. The window is closing.