CITM5040 - General Conditions: Acquisition of partnership share

FA02/SCH16/PARA17; ITA/s352

Tax relief under the CITR scheme is not available in respect of any investment that represents capital contributed by an investor on becoming a member of a Community Development Finance Institution (CDFI) that is constituted as a partnership.

Such capital contributions include any amount which:

• purports to be provided as loan capital, and
• is accounted for as partners’ capital in the partnership accounts.