CITM6140 - Tax Relief: Attribution

CTA2010/Part 7/Chapter 4/S240; ITA/s357

Where, within a single tax year or accounting period, an investor has made a number of different investments under the CITR scheme it may be necessary to be able to determine how the relief obtained is allocated, or attributed between those investments. This would also be necessary, for example, if there were a part disposal of an investment that had attracted relief.

The attribution rules work as follows:

Allocation Required	Method of Allocation
Between two or more investments	Allocate relief in proportion to invested amounts (see CITM6090).
Between shares (or securities) within the same issue	Allocate the relief evenly across all the shares (or securities).
Between shares originally subscribed for and bonus shares issued in respect of the original shares	Relief attributable to the original shares is attributed across the combined holding of bonus and original shares. The CITR scheme rules then apply as if the original issue had included the bonus shares.
On withdrawal of relief attributable to a loan, or any securities or shares	The relief attributable to that loan, or each of those securities or shares, is reduced to nil.
On reduction of relief attributable to a loan or any securities or shares	The relief attributable to that loan, or each of those securities or shares, is reduced by a proportionate part of that reduction.