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HMRC internal manual

Community investment tax relief manual

Withdrawal of relief: Disposal of loan

CTA2010/Part 7/Chapter 5/S243; ITA/s360

If, within the five year period beginning on the day the loan was made an investor disposes of the whole or part of the loan (other than as a permitted disposal) any community investment tax relief attributable to that loan, for any year or period, must be withdrawn.

A disposal is permitted if it is:

  • by way of a distribution in the course of dissolving or winding up the community development finance institution (CDFI);
  • a disposal by reason of the entire loss, destruction, dissipation or extinction of the loan (TCGA92/s24(1))
  • a deemed disposal because the loan has become of negligible value (TCGA92/s24(2)), or
  • made after the CDFI has ceased to be accredited.