Corporation Tax Act 2010 section 221

Meaning of "making an investment"

Section 221 defines what counts as "making an investment" in a Community Development Finance Institution (CDFI) for the purposes of the community investment tax relief rules.

  • A company makes an investment when it lends money (whether secured or unsecured) to a CDFI, or when it subscribes for an issue of the CDFI's securities or shares.
  • Providing overdraft facilities to a CDFI does not count as making a loan for these purposes.
  • Subscribing for or acquiring the CDFI's securities is not treated as making a loan (though it may qualify as an investment under the shares or securities route instead).
  • Where a loan agreement allows the CDFI to draw down amounts over time, the loan is treated as made on the date the first amount is drawn down.

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