Corporation Tax Act 2010 section 239

Accreditation of investor

Section 239 prevents a corporate investor from making community investment tax relief claims if it becomes accredited as a Community Development Finance Institution (CDFI) during the five-year investment period.

• If a corporate investor becomes accredited as a CDFI during the five-year period, it loses entitlement to claim community investment tax relief from a specified accounting period onwards.
• No claim may be made for the relevant accounting period or any later accounting period — the restriction is permanent from that point forward.
• If accreditation occurs within the first year of the five-year period, the cut-off is the accounting period in which the original investment date fell, meaning all relief is lost.
• If accreditation occurs later, the cut-off is the accounting period containing the last anniversary of the investment date before accreditation, or the anniversary itself if accreditation falls exactly on one.