Corporation Tax Act 2010 section 661C

Periods over which management condition treated as met

Section 661C sets out the circumstances in which HMRC may treat the management condition for a community amateur sports club (CASC) as being satisfied, even where a manager of the club was not a fit and proper person during a particular period.

• The management condition requires that each manager of a CASC is a fit and proper person; where this is not met for any period, HMRC has discretion to treat the condition as still satisfied.
• HMRC may treat the condition as met if the failure did not prejudice the purposes of the club.
• Alternatively, HMRC may treat the condition as met if it is just and reasonable in all the circumstances to do so.
• Only one of these two grounds needs to be satisfied for HMRC to exercise this discretion in the club's favour.