Corporation Tax Act 2010 section 479

Meaning of "charitable trade"

Section 479 defines what qualifies as a "charitable trade" for corporation tax purposes, and explains how mixed-purpose trades are split and apportioned.

  • A trade is a charitable trade if it is carried out in pursuit of the charity's primary purpose, or if the work is mainly done by the charity's beneficiaries.
  • Where a trade is only partly carried out for the charity's primary purpose, the primary-purpose part and the other part are treated as two separate trades.
  • Similarly, where beneficiaries carry out some but not most of the work, the beneficiary-worked part and the remainder are treated as two separate trades.
  • When a trade is split into separate trades, a just and reasonable apportionment must be made of expenses, receipts, and any post-cessation receipts.

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