Corporation Tax Act 2010 section 244

Disposal of securities or shares during 5 year period

Section 244 deals with the withdrawal or reduction of Community Investment Tax Relief (CITR) when an investor disposes of all or part of an investment in securities or shares within the 5 year period.

  • If an investor disposes of securities or shares within the 5 year period while the CDFI remains accredited, and the disposal is not a qualifying disposal (i.e. not at arm's length or a permitted disposal), all CITR attributable to the disposed investment must be withdrawn in full.
  • If the disposal is a qualifying disposal and the total CITR claimed does not exceed 5% of the sale consideration ("A"), all of that CITR must still be withdrawn.
  • If the disposal is a qualifying disposal and the total CITR exceeds "A", the excess over "A" is withdrawn, with relief given in later accounting periods being reduced before relief given in earlier periods.
  • Where the total CITR claimed is less than 5% of the original invested amount for the relevant period, "A" is reduced proportionally by multiplying it by the fraction of total CITR over 5% of the invested amount.

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