Interest-rate capital income is not within the scope of business relief, which would otherwise lead to a tax of up to $5 million (5.7 million euros) with an effective rate of 10%, since the extent of this relief is too narrow to include it. In addition, the acquisition of a right of conduct is considered to be an acquisition of securities within the meaning of UK occupational health and safety legislation. However, in practice, this only becomes problematic if the contractors do not acquire their rights at the beginning of the fund or fall under the so-called „safe harbor“ rules agreed between the HMRC and the BVCA. The typical interest rate is 20% for private equity and hedge funds. Carlyle Group and Bain Capital are outstanding examples of private equity funds that require transferred interest. However, these funds have recently calculated higher sustained interest rates of up to 30% for so-called super carry. However, there is favourable tax treatment for investment companies in the EU, Iceland or Norway (qualified legal systems). Under this scheme, a capital gains tax rate of 30.1% applies, under certain conditions, to the share of capital in capital gains distributions made by qualified investment firms. The transferred interest is not automatic; it is created only if the fund generates profits exceeding a certain level of return, often referred to as the obstacle rate. If the performance of the obstacle is not reached, the Compleifnichter will not receive a promotion, although sponsors receive their proportionate share. Carry can also be „applauded“ if the fund is cross-referenced.
The 2003 Finance Act expanded the circumstances in which investment gains were considered employment-related and were therefore taxed as income. In 2003, domestic income and BVCA entered into a new agreement which, despite the new legislation, maintained the taxation of most interest-related profits as capital gains and not as income.  These capital gains were generally taxed at 10%, compared to a 40% rate on income. Critics of the transferred interest system (unlike critics of broader private equity tax regimes) are primarily opposed to the director`s ability to view his overall return as a capital gain, including amounts in excess of the amount directly related to the capital provided by the manager. Critics call it managers who exploit tax loopholes to get a salary without paying the normal 37% of marginal income. [Citation required] This controversy has been going on since the mid-2000s.