We advise investors to seek independent tax advice with respect to the local tax treatment of their investments on the Odin platform. The below is not tax advice and cannot be used as such - it is for informational purposes only.

We have received guidance indicating that UK investors are likely to be liable for income tax on carried interest, since typically Odin SPVs are not collective investment schemes, are not regulated AIFM structures, and as such do not benefit from the carve outs of DIMF rules mentioned below.

However, if structures are run as AIFMs, carried Interest returns in the UK may benefit from different treatments. Effectively, sums allocated to an individual by way of carried interested can be treated, for tax purposes, as if the recipient had personally carried out the underlying transaction that gave rise to the income. The carried-interest Income Tax rules provide broadly, that any sum of carried interest arising from a fund is eligible for capital gains tax treatment only if the investment vehicle holds investments, on average, for at least 40 months. Partial CGT treatment is available where the average holding period is between 36-40 months. Where the average holding period is below three years, all sums of carried interest arising to the individual − however structured − are charged to tax and NICs as trading profits.