Corporation Tax Act 2010 section 251

Value received if there is more than one investment

Section 251 explains how to apportion value received from a Community Development Finance Institution (CDFI) across multiple investments for the purposes of Community Investment Tax Relief (CITR), and how to calculate the relevant amounts for each investment type.

• When an investor holds two or more CITR-qualifying investments in a CDFI and receives value falling within the six-year periods of more than one investment, that value must be split between the relevant investments rather than applied in full against each one.
• The apportionment uses the fraction A/B, where A is the "appropriate amount" for the investment in question and B is the total of the appropriate amounts for all the investments whose six-year periods cover the receipt of value.
• For loan investments, the appropriate amount is the average capital balance of the loan — calculated as the mean of daily outstanding balances — for the second year of the six-year period (if value is received in year one or two) or for the year in which the value is received (if later), ignoring the receipt of value itself when computing that balance.
• For investments in securities or shares, the appropriate amount is the full subscription price if value is received in the first year, or, in later years, the subscription price of those securities or shares that the investor still holds as sole beneficial owner continuously since the investment was made.