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Hedge Fund X-Ray

What a hedge fund leaves a UK investor

The full cascade of management fee, hurdle, high-water mark and performance fee, then UK tax on income and gains, then the gross return the fund would need for you to keep what you want.

By Eldar Edmond Grady, CEO, PPLI.com · Research checked 23 September 2026

The instrument runs in your browser and needs JavaScript. The method and the worked examples below are written out in full and read without it.
Context

The reported figure stops before your tax

A hedge fund reports its return net of its own fees. Your tax comes after that, and for a UK resident it depends on how the return arrives: income at the savings rate, realised gains at 24%, and gains on a non-reporting offshore fund taxed as income.

Inside a policy the tax layer is deferred, but only where the fund counts as permitted property or is picked by an insurer-appointed manager you do not direct; the manager's fees are due either way. Outside a policy the whole tax layer applies, and the instrument shows it year by year.

A worked case, hypothetical

£1,000,000, one year, 10% gross, 2 and 20

No hurdle. Fund fees treated as not deductible, so the taxable result is the 10% before fees.

The same fund, three tax positions
Value after fees 1,000,000 + 100,000 − 20,000 − 16,000 = £1,064,000 Reporting fund, 24% on 100,000 tax 24,000 kept £1,040,000 Non-reporting fund, 45% on 100,000 tax 45,000 kept £1,019,000 Non-reporting fund, higher rate 40% tax 40,000 kept £1,024,000

Set the share of gains taxed as income to 100 for a non-reporting fund. The difference between the first two lines is £21,000 on one year and one fund.

The calculation

How the X-Ray works

The fee waterfall

Management fee on the opening value; performance fee on the profit after it, above the high-water mark and any hurdle (hard or soft).

Tax

Income share at the savings rate; realised gains at the gains rate, which blends the CGT rate and the savings rate by the share of gains taxed as income; unrealised growth taxed on closing the position.

Solving backwards

The required gross return is found by trying gross returns until the net result matches your target. It is the same model run in reverse.

Questions

Common questions

Why are fees not deducted before tax?

The model treats fund fees as not deductible, so you are taxed on the result before fees. Actual treatment depends on the fund and its reporting.

PPLI.com is not authorised by the Financial Conduct Authority and does not give personal advice. This is general information about UK law, not an invitation or inducement to enter into any insurance or investment contract. Policies issued by insurers outside the UK are not protected by the Financial Services Compensation Scheme (unless written through a UK branch).

Sources and authorities

The authorities this page relies on

HMRC helpsheet HS265

A gain on disposal of a non-reporting offshore fund is normally an offshore income gain, charged to income tax. A gain on a reporting fund is charged to capital gains tax. gov.uk, HS265

Income tax, savings and dividend rates

Savings rates 20, 40 and 45% in 2026/27. Dividend rates 10.75, 35.75 and 39.35% from 6 April 2026. Savings rates of 22, 42 and 47% from 6 April 2027 (FA 2026 s.5), shown here only as a labelled option. gov.uk, rate changes

Capital gains tax rates

18 and 24% for disposals on or after 30 October 2024. Business Asset Disposal Relief at 18% from 6 April 2026. Annual exempt amount £3,000. gov.uk, CGT rates

Personal portfolio bonds, ITTOIA ss.516, 520 and 522

A policy is a personal portfolio bond if the holder, a connected person or someone acting for them can select the assets outside the permitted categories in s.520. At the end of each insurance year except the last, a deemed gain of 15% of premiums plus earlier deemed gains is taxed, with no top-slicing relief. legislation.gov.uk, s.522

IPTM7725 and IPTM7730

An insurer-appointed manager normally avoids personal portfolio bond status, but a mandate restricted so tightly that the policyholder's instructions in effect determine the assets is treated as selection by the policyholder. gov.uk, IPTM7730

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Eldar Edmond Grady
Author
Eldar Edmond Grady
CEO, PPLI.com
Checked against UK primary sources. The statutes, HMRC manual paragraphs and regulator pages cited are linked in the text so each statement can be read beside its basis.
Last updated: 23 September 2026
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