Corporation Tax Act 2010 section 240

Attribution: general

Section 240 sets out the general rules for attributing community investment tax relief (CITR) to specific loans, securities or shares, so that the correct amount of relief can be identified if it later needs to be withdrawn or reduced.

• Where a corporation tax reduction arises from a single loan or a single issue of securities or shares, the full amount of that reduction is attributed to that loan or those securities or shares.
• Where the reduction arises from two or more investments, it is apportioned between them in proportion to the invested amounts for the period.
• Where a reduction is attributed to securities or shares within the same issue, each individual security or share carries a proportionate part of the attributed amount.
• If CITR is withdrawn under the rules in Chapter 5, the relief attributed to the relevant loan, securities or shares is reduced to nil; if it is only partly reduced, each security or share bears a proportionate part of that reduction.