Government confirms 60 day grace period for non-UK resident investment managers to perform investment management services in the UK

Under the revised regime, the amount of carried interest subject to income tax and NICs will be adjusted by a multiplier of 72.5% where qualifying conditions are met, delivering an effective tax rate of 34.075%.

The government has confirmed today that it will implement limitations on the territorial scope of the revised regime such that any investment management services performed in the UK by a non-UK resident individual will not be subject to UK tax where the individual spends fewer than 60 days in the tax year performing investment management services in the UK. In addition, a non-UK resident investment manager may be entitled to relief under a double tax treaty if they do not have a fixed place of business in the UK.

Following the consultation on the draft legislation published in July 2025, we understand that a number of changes have been made, with the revised draft legislation due to be published next week. 

Authored by Elliot Weston.