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This website provides comprehensive information about how charities and donors are taxed in the UK.

If you are looking for a quick answer to a simple question, we recommend you try HMRC tax guidance for charities.

However, if you are looking for a deeper analysis or an impartial view you are in the right place.

Most of this website requires you to login. To obtain a login licence you need a copy of the book associated with this site, Taxation of Charities and Nonprofit Organisations, and you can then register for the life of the edition and login.

You can however access the introduction and chapters 1 and 2, which concern general policy issues, without logging in.

Users may also contribute to the text or correct slips or errors, and if you see anything that needs correcting or expanding, please do. A copy of the next edition of our book will be given to the user who makes the most edits. User contributions are reviewed by Mary Ashley.

Contents of ToC online

ToC Online is the online version of the book Taxation of Charities and Nonprofit Organisations by James Kessler QC and Oliver Marre. The initial data was the current edition of the book, published September 2015.

1 Policy Issues in Charity Taxation
2 Tax Avoidance and Evasion
3 Definitions of Charity
4 Taxation of Charity Income
5 Taxation of Charity Capital Gains
6 Charitable Expenditure Rules
7 Tainted Donation Rules
8 Trading by Charities
9 Trading Companies held by Charities
10 Business Sponsorship and Advertising
11 Corporate Charities
12 Employees and Beneficiaries of Charities
13 Acquisition of Companies
14 Double Taxation Treaties and Charities
15 Cash Gifts from Individual to Charity (Gift Aid)
16 Gift Aid Small Donation Scheme
17 Corporate Gift Aid
18 Giving by Business to Charity
19 Payroll Giving Scheme
20 Interest-Free Loans to Charity
21 Gift of Shares and Land to Charity
22 Gifts of Works of Art to Charity
23 Capital Gains Tax Relief on Disposals to Charity
24 Inheritance Tax Reliefs on Transfers to Charity
25 Charity Legacy Relief
26 Will Drafting
27 Charitable Gift of Share of Residue: Benham Issues
28 Obtaining IT and IHT Reliefs on Gift by Will or IoV
29 Variation of Wills
30 Benefits for Donors
31 Trusts with Some Charitable Element
32 Payments to Charity From Non-resident Trusts
33 Estates of Deceased Persons: CGT
34 Estates of Deceased Persons: Income Tax
35 VAT: Basic Concepts
36 Recovery of Input VAT
37 VAT: Exemption
38 VAT: Zero Rating
39 Stamp Duties
40 Rating Relief
41 Community Amateur Sports Clubs
42 Political Parties
43 Housing Associations
44 Local Authorities
45 Administration: Tax Returns and Claims
46 Appendix 1: International Entities: Approved Charitable Investments
47 Appendix 2: HMRC Model Gift Aid Declarations
48 Appendix 3: Retail Gift Aid: Template Letters
49 Appendix 4: Substantial Donor Rules
50 Appendix 5: Bibliography
51 Appendix 6: How to Improve the Taxation of Charities
52 Appendix 7: Deemed Charities and Eligible Bodies
53 Appendix 8: CASCs: Eligible Sports

If you want further advice

If you do not find the answer to your question in ToC online, or if you want advice on which you can legally rely, you may instruct James Kessler QC or Oliver Marre to advise. For further information see How to instruct James Kessler QC and Oliver Marre.

ToC archive editions

There are archive editions for ToC 2009/10, 2011/12 and 2013/14. These will occasionally be useful to investigate the tax position in those years, but the current edition will generally be the best starting point, as that has been written in the light of current HMRC guidance, and further thought and research.


If you have technical problems, or problems logging in click here

To contact James Kessler QC click here

To contact Mary Ashley, who reviews users online contributions, click here

To contact the publishers of Taxation of Charities and Nonprofit Organisations click here

For multiple user licences, or to install on a firm's intranet contact the publishers

Technical notes

ToC online is in technical terms a Wiki on the lines of Wikipedia, but only registered users can edit this Wiki.

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