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HMRC internal manual

Community investment tax relief manual

Tax Relief: Corporate Investors - limit on State aid

CTA2010/Part 7/Chapter 1/S220B

CITR is no longer a notified State aid but operates as a de mimimis aid under Article 2 of the Commission Regulation (EC) No 1998/2006. As a consequence it is necessary to limit the amount of relief corporate investors can receive to comply with the de minimis limit of €200,000 in any three year period. This limit is being introduced for investments made on or after 1 April 2013. Investments made before that date can be ignored for the purposes of this section.

Investment into CDFIs can be made either by equity or by loan. Different calculations will apply depending on the method of investment.

Relief under CITR is given over a five year period, but the de minimis calculation will only require a company to take account of a three year period and not the whole amount of the relief due in the full period. The three year period will be that ending at the end of the current accounting period.

The three year period for any particular investment will run past the five year tax relief period and may need therefore to be taken into account for subsequent investments.