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

If you are just looking for a quick answer to a simple point, we recommend the HMRC tax guidance for charities.

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

To enter this website you need an account.

If you have not (yet) bought the book associated with this site, Taxation of Charities and Nonprofit Organisations, you may register for a free one day trial. There is no charge for a one day trial account, but if you find the site useful, the authors invite you to make a donation to the charity Water Aid.

If you have bought a copy of the book, you can register for the edition and login.

You may enter this site once you have registered and logged in by clicking on the index below, or you can search the text.

Users may also contribute to the text 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 Oliver Marre.

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 2013.

  1. Policy Issues in Charity Taxation
  2. Definitions of Charity
  3. Taxation of Charity Income
  4. Taxation of Charity Capital Gains
  5. Charitable Expenditure Rules
  6. Tainted Donation Rules
  7. Trading by Charities
  8. Trading Companies held by Charities
  9. Business Sponsorship and Advertising
  10. Corporate Charities
  11. Employees and Beneficiaries of Charities
  12. Extracting Value from Companies
  13. Acquisition of Companies
  14. Double Taxation Treaties
  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. Relief for Gift of Shares and Land to Charity
  22. Relief for 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. Value Added Tax: Basics
  36. VAT: Exemption
  37. VAT: Zero Rating
  38. Stamp Duties
  39. Rating Relief
  40. Community Amateur Sports Clubs
  41. Political Parties
  42. Housing Associations
  43. Local Authorities
  44. Administration: Tax Returns and Claims
  45. Appendix 1: International Entities: Approved Securities
  46. Appendix 2: HMRC Model Gift Aid Declarations
  47. Appendix 3: Substantial Donor Rules
  48. Appendix 4: Bibliography
  49. Appendix 5: How to Improve the taxation of Charities
  50. Tables

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 and 2011/12. This 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 substantially rewritten 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 Oliver Marre, who reviews users online contributions, click here

To contact the publishers of Taxation of Charities and Non-profit 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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