A £264m construction scheme whose investors include the England manager, Roy Hodgson, and other celebrities does not have a single tenant signed up, more than two years after a controversial tax relief deal was struck, the Guardian can reveal.

Margaret Hodge, chair of the Commons public accounts committee, said the lack of tenants for two data centres on the Cobalt business estate near Newcastle fuelled the perception that the scheme was aimed at tax avoidance. She said the enterprise zones that had enabled the tax relief should have been about job creation, not exploited by "greedy individuals".

Hodgson, Arsenal's manager, Arsène Wenger, and the Manchester United striker Wayne Rooney were among those who collectively invested to buy the buildings – which house computer servers – in April 2011, receiving tax relief at the then 50% top rate. The scheme took advantage of generous tax reliefs for building projects in enterprise zones before they were abolished in April 2011 and replaced with different allowances. The project's marketing brochure promised a £1.66 "cash flow benefit" from HM Revenue and Customs (HMRC) for every £1 put in by investors.

The involvement of Hodgson, Wenger, Rooney and the comedian Jimmy Carr was exposed when the Cobalt deal was signed. The Guardian can reveal that the Everton players Marouane Fellaini, Nikica Jelavic and Sylvain Distin also invested, along with Arsenal's Mikel Arteta and Leon Angel, agent for Hodgson and Wenger.

Critics argue that the sort of returns delivered by the Cobalt schemes, in which HMRC paid the investors more in tax relief than the money they put into the project, were never intended when enterprise zones were conceived in the 1980s to attract businesses to areas where traditional industry had shrunk. The scheme's organisers strongly defended it, saying the critical time to market the data centres to businesses was after they had been established.

The 674 Cobalt investors paid an average £117,000 each, £79m collectively, or 30% of the £264m total cost of buying the data centres. The remaining 70%, £185m, was borrowed from Bank Winter of Vienna.

Although they put in only part of the cost, the wealthy investors were entitled under the enterprise zone rules to the full 50% tax relief on the £264m purchase price – £132m. After a small amount of tax, the investors made a £52m profit from HMRC, paid soon after the deal was concluded in April 2011.

Margaret Hodge said enterprise zones were intended to create jobs. Photograph: Reuters TV/Reuters

Hodge said: "It is deeply depressing to find greedy individuals exploiting a perfectly proper government objective, to line their pockets. Enterprise zones aimed to create jobs, not to enable rich people to get more money back in tax than they invested." Martin Taylor of Rebus Investment Solutions, a firm advising investors in collective schemes such as this that have performed badly, said the absence of signed-up tenants two years after it opened indicated insufficient demand. "Huge money, around £600m, suddenly went into data centres just before the old enterprise zone allowances were abolished," Taylor said. "You have to question whether the demand was there for three data centres in the same location [another was built by other investors], or whether they were principally to shelter tax.

"We are advising many people, including several former footballers, who have faced calls for cash and suffered serious financial difficulties after promised returns from schemes were not delivered."

Nick Astaire of Harcourt Capital, the scheme's organiser, said investors such as Hodgson, Wenger, Rooney and Carr were bringing regeneration to the north-east. He said the highly technical nature of data centres meant prospective tenants did not consider them until they were built, and "the critical marketing period starts now". Although Astaire accepted that the investors profited from 50% tax relief on the entire £264m purchase price while only investing £79m, he said it was a genuine venture. It must secure tenants or the bank could call in its loan and HMRC would claw back the tax relief.

"The rates at which you could borrow were different in the 1980s," Astaire acknowledged, "but the rules remained the same: tax relief was due on the total asset price. It is quite subjective whether people think the tax relief is excessive; our view is we are following legislation and guidance, and the tax relief is appropriate. The 50% tax rate was an added incentive, which created a superior cash-flow benefit. But these investors are not exploiting loopholes; they are taking a commercial risk investing in an area where it is needed. The data centres may not employ many people directly, but can attract other businesses. We believe the risk taken is commensurate with the investors' reward."

David Palmer, of UK Uncut, which campaigns for the wealthy to pay tax in full, described the scheme as a disgrace. "I'm sure the country could have benefited much more from the public money [£132m] being spent in other ways," he said. "I don't believe Roy Hodgson is setting a very good example as the England manager by being involved in it."

Astaire said HMRC was "currently reviewing the claim for tax relief, which is fairly standard procedure" but it had not withheld any tax relief from investors.

The Football Association, Hodgson's employer, declined to comment on his involvement, saying: "This is a private matter." FA sources stressed that Hodgson was only one of many people who invested, and they had not broken any rules. Angel, on behalf of Hodgson and Wenger, said: "Our clients are pleased to invest in government-backed regeneration programmes which will hopefully help to generate new jobs in these areas."

Rooney's representative declined to comment. Everton and Arsenal said their players' investments were private matters. The representatives of Fellaini, Arteta, Jelavic and Distin did not respond to questions about the scheme; nor did Chambers Management, Carr's agency.