CTA2010/s226 & ITA/s345 set out conditions that a loan must satisfy if it is to be eligible for relief under the CITR scheme. These include limits on the extent to which a loan may be repaid during the five year period beginning on the day the loan was made (the ‘five year period’). If these limits are exceeded by other than an amount of insignificant value (see below) then any relief obtained in respect of the loan is withdrawn.
Specifically, relief is withdrawn if
•during the final three years of the five year period