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HMRC internal manual

Community investment tax relief manual

General conditions applying to investors and investments: Beneficial ownership

CTA2010/Part 7/Chapter 3/S232; ITA/s351

Tax relief under the CITR scheme is only available, if at the time the investment is made, the investor is sole beneficial owner of the investment.

Where the investment is a loan, the beneficial owner is regarded as being the person beneficially entitled to the repayments of that loan.