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HMRC internal manual

Community investment tax relief manual

Qualifying investments: Limit of issue of tax relief certificates

CTA2010/Part 7/Chapter 2/S229; ITA/s348

There are limits on the amount of tax relief certificates that a community development finance institution (CDFI) can issue during any period of accreditation (see CITM2030) in respect of investments made during that period.

There are separate limits for retail and wholesale CDFIs (see CITM2050):

  • Retail CDFIs: Any body accredited as a retail CDFI must not, during any accreditation period, issue tax relief certificates in respect of investments whose aggregate value exceeds £10 million
  • “Wholesale” CDFIs: Any body accredited as a wholesale CDFI must not, during any accreditation period, issue tax relief certificates in respect of investments whose aggregate value exceeds £20 million

If these limits are exceeded the tax relief certificates issued by the CDFI during that period which caused the limit to be exceeded are invalid.

For these purposes the value of investments is determined as follows:

  • loans: the amount of the loan, or, where the loan agreement allows for amounts to be drawn down over a period or time, the amount committed under the agreement
  • shares & securities: the amount subscribed.

The limits on the amount of tax relief certificates that can be issued in any period may be varied by order of the Treasury. Any such order will specify the accreditation periods for which they will take effect. If the amounts are increased the order may specify that they shall apply to accreditation periods that have started before the order takes effect.