SolvedCITM5020 | General conditions applying to investors and investments: Beneficial ownership
From HM Revenue & Customs · Community investment tax relief manual
CTA2010/Part 7/Chapter 3/S232; ITA/s351
Tax relief under the CITR scheme is only available, if at the time the investment is made, the investor is sole beneficial owner of the investment.
Where the investment is a loan, the beneficial owner is regarded as being the person beneficially entitled to the repayments of that loan.