Section 357 | Attribution: general

(1)In this Part references to the CITR attributable to any loan, securities or shares in respect of a tax year are read as references to the reduction which—

(a)is made in the investor's liability to income tax for that year, and

(b)is attributed to that loan, or those securities or shares, in accordance with this section and section 358.

This is subject to the provisions of Chapter 6 for the withdrawal or reduction of CITR.

(2)Subsections (3) and (4) apply if the investor's liability to income tax is reduced for a tax year under this Part.

(3)If the reduction is obtained because of one loan, or securities or shares included in one issue, the amount of the tax reduction is attributed to that loan or those securities or shares.

(4)If the reduction is obtained because of a loan or loans, securities or shares included in two or more investments, the reduction—

(a)is apportioned between the loan or loans, securities or shares in each of those investments in the same proportions as the invested amounts in respect of the loan or loans, securities or shares for the year, and

(b)is attributed to that loan or those loans, securities or shares accordingly.

(4A)In the case of CITR under section 335A, in subsection (4)(a) the reference to the year is to be read as a reference to the year mentioned in section 335A(1)(a).^F1

(5)If under this section an amount of any reduction of income tax is attributed to any securities in the same issue, a proportionate part of that amount is attributed to each security.

(6)If under this section an amount of any reduction of income tax is attributed to any shares in the same issue, a proportionate part of that amount is attributed to each of those shares.

(7)If CITR attributable to a loan or any securities or shares falls to be withdrawn under Chapter 6, the CITR attributable to that loan or each of those securities or shares is reduced to nil.

(8)If CITR attributable to any securities or shares falls to be reduced under that Chapter by any amount, the CITR attributable to each of those securities or shares is reduced by a proportionate part of that amount.