Income Tax Act 2007 section 549

Transactions with substantial donors

Section 549 defines what counts as a "substantial donor transaction" and sets out when a person is treated as a substantial donor to a charitable trust.

• A person who gives £25,000 or more to a charitable trust within any 12-month period is classified as a substantial donor for up to three consecutive tax years, plus a further five tax years after that period ends.
• A person who gives £100,000 or more over any six-year period is classified as a substantial donor for up to 13 consecutive tax years, plus a further five tax years after that period ends.
• References to a charitable trust include charities that are connected with it, and references to a substantial donor include persons connected with that donor.
• The substantial donor status therefore has a long tail — once triggered, it can apply for many years beyond the period in which the donations were actually made.