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HMRC internal manual

Community investment tax relief manual

General conditions applying to investors and investments: Acquisition of partnership share

CTA2010/Part 7/Chapter 3/S234; ITA/s352

Tax relief under the CITR scheme is not available in respect of any investment that represents capital contributed by an investor on becoming a member of a Community Development Finance Institution (CDFI) that is constituted as a partnership.

Such capital contributions include any amount which:

  • purports to be provided as loan capital, and
  • is accounted for as partners’ capital in the partnership accounts.