CITM7100 - Withdrawal of Relief: Aggregation of receipts of insignificant value

FA02/SCH16/PARA34; ITA/s365

The CITR rules dealing with value received ( CITM7060) ignore receipts of ‘insignificant value’. These are defined as amounts of value less than £1,000 or which may be regarded as insignificant in relation to the overall amount of the loan, or the amount subscribed for the shares or securities, to which they relate. For the purpose of this test, 'insignificant' should be given its dictionary meaning of 'trifling or completely unimportant’. So in most cases it is very unlikely to cover any amount in excess of £1,000. Cases of doubt should be referred to CT&VAT (Technical).

But where an investor who receives a receipt of insignificant value during the six year period (the ‘period of restriction’) commencing one year before the investment date has earlier in that period received other receipts of insignificant value, the values of all such receipts received up to that time are aggregated. If the value of the aggregated amount is an amount of insignificant value then the latest receipt is disregarded. But if the aggregate receipts are not insignificant the investor is treated as receiving value of an amount equal to the aggregate amount at that time.