Corporation Tax Act 2010 section 248

Receipts of insignificant value to be added together

Section 248 requires small amounts of value received from a CDFI to be aggregated, so that individually insignificant receipts cannot be used to avoid the withdrawal or reduction of Community Investment Tax Relief.

• Individual receipts of value from the CDFI that are each of insignificant value must be accumulated together with the current receipt during the six-year investment period
• If the running total exceeds the insignificant value threshold, the entire aggregated amount is treated as a single receipt of value at the time of the latest receipt, potentially triggering a reduction or withdrawal of CITR
• A receipt counts as insignificant if it is no more than £1,000, or if above £1,000 it is insignificant relative to the average loan balance or the subscription amount for shares or securities
• Once a receipt has been included in a total that breached the insignificant value threshold, it cannot be counted again in any future aggregation