Income Tax Act 2007 section 357

Attribution: general

Section 357 sets out the general rules for attributing Community Investment Tax Relief (CITR) to specific loans, securities or shares, so that any income tax reduction an investor receives can be traced back to the particular investment that gave rise to it.

• When a tax reduction arises from a single loan or a single issue of securities or shares, the full amount of the reduction is attributed to that loan, or those securities or shares.
• When a tax reduction arises from two or more investments, the reduction is split between the loans, securities or shares in proportion to the amounts invested in each for the relevant year.
• Where securities or shares form part of the same issue, the attributed amount is divided equally among each individual security or share on a pro-rata basis.
• If CITR must later be withdrawn or reduced under Chapter 6, the attributed relief for the affected loan, securities or shares is either set to nil (full withdrawal) or reduced proportionately (partial reduction).