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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 the HMRC tax guidance for charities.

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

To use 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, and wish to express support or thanks, 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 life of 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 or post comments, 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 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
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 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 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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