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- Trading income exemptions

"The Taxes Acts provide for a limited exemption from Income Tax or Corporation Tax for the profits of trades carried on by charities. To qualify for exemption the profits must be used solely for the charitable purposes of the charity and the trade must satisfy at least 1 of the following 3 conditions, the:

trade’s a charitable trade (either primary purpose or mainly carried out by beneficiaries — paragraph 6) or is ancillary to carrying out a primary purpose of the charity (see paragraph 7)
non-charitable trading turnover falls below the charity’s small trading turnover limit (see paragraph 14)
trading activity is a VAT exempt fundraising event (paragraph 29)
If a trade does not satisfy one of the above conditions, the profits of the trade will not be exempt from tax regardless of whether or not the profits are used for the purposes of the charity." (Annex iv)

Legislation: 

Cases: 

HMRC manuals: 

Commentary: 

See also:

 © 2025 by Michael Firth, Gray's Inn Tax Chambers

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