IFM36532 - Carried interest and profit related returns: The "no significant risk" test: Allocation of sums treated as disguised fees after application of no significant risk test

Allocation of sums treated as disguised fees after application of no significant risk test

ITA07/S809EZC(7)-(8)

The minimum amount (IFM36531) which does not pass the no significant risk test will not be carried interest and will be considered as a disguised fee (IFM36300). The minimum amount is apportioned between the sums that have arisen as follows:

• Where so much of the minimum amount is attributable to a particular actual sum it is to be apportioned to that actual sum.
• Where the minimum amount is not attributable to any particular sum it should be apportioned on a just and reasonable basis.