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This site provides comprehensive information about the taxation of charities and tax reliefs for gifts to charity.

If you are looking for a quick answer to a straightforward question, we recommend HMRC tax guidance for charities or HMRC detailed guidance notes.

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



1 Policy Issues in Charity Taxation
2 Tax Avoidance and Evasion
3 Definitions of "Charity"
4 Taxation of Charity Income
5 Taxation of Charity Gains
6 Charitable Expenditure Rules
7 Tainted Donation Rules
8 Trading by Charities
9 Companies held by Charities
10 Business Sponsorship and Advertising
11 Charitable Companies
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 Donations Scheme
17 Corporate Gift Aid
18 Giving by Businesses to Charity
19 Payroll Giving Scheme
20 Interest-Free Loans to Charity
21 Gifts of Shares/Land to Charity
22 Gifts of Works of Art to Charity
23 CGT Relief on Disposals to Charity
24 Inheritance Tax Reliefs for Charities
25 Charity Legacy Relief
26 Will Drafting
27 Share of Estate Given to Charity: Benham Issues
28 Obtaining Income Tax 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 Sports Clubs
42 Clubs and Mutual Concerns
43 Political Parties
44 Housing Associations
45 Local Authorities
46 Social Investment Relief
47 Administration: Tax Returns and Claims


Appendix 1: International Entity Securities: Approved Charitable Investments
Appendix 2: Model Gift Aid Declarations
Appendix 3: Retail Gift Aid: Template Letters
Appendix 4: CASCs: Eligible Sports
Appendix 5: Deemed Charities and National Bodies
Appendix 6: Accreditation of Social Impact Contractors
Appendix 7: Substantial Donor Rules
Appendix 8: How to Improve the Taxation of Charities
Appendix 9: Bibliography

2022/23 edition

This site contains the text of the 2022/23 edition of Taxation of Charities and Nonprofit Organisations. A paper version of the book will be out very shortly.

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Most of this site requires you to login.

To obtain a login licence you need to order 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.
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, but if you find the site useful, and wish to express your thanks, the authors invite you to make a £10 - £20 donation to the charity Water Aid.
Without logging in you can access:
Chapter 1 Policy Issues in Charity Taxation
Chapter 2 Tax Avoidance and Evasion

Comments please

Users may also contribute to the text, and if you can add anything, or spot anything that needs to be corrected, 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 Jon-Selous Borlace.

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 any of the authors to advise. They are James Kessler QC, Etienne Wong and Jon-Selous Borlace. See How to instruct James Kessler QC, Etienne Wong and Jon-Selous Borlace.

Archive editions

There are archive editions for years from 2005/06. These will 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 Etienne Wong, who is responsible for the VAT chapters, click here

To contact Jon-Selous Borlace, who reviews online contributions, click here

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

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Technical notes

ToC Online is a Wiki on the lines of Wikipedia, but only registered users can edit the text.

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To access the ToC reference material, click here ToC Resource Archive