Taxation of Charities and Nonprofit Organisations 11th Edition

Taxation of Charities and Nonprofit Organisations 11th Edition

Published November 2017


ISBN: 978-1-901614-72-5

Publication date: 20/11/2017

Price: £180.00

Price (Charity): £99.00

Taxation of Charities and Nonprofit Organisations 11th Edition

by James Kessler QC, Etienne Wong and Mary Ashley

(all of Tax Chambers 15 Old Square, Lincoln's Inn, London WC2A 3UE),

published November 2017

ISBN 978-1-901614-72-5 

The book comes with a free single user licence for the online version 'ToC online'.

For a multiple user licence, contact the publishers.


The Authors


James Kessler QC practises at the Tax Bar. He was appointed QC in 2003. He is also a member of the Bar of Northern Ireland.

James advises in particular on charities, offshore entities, trusts, wills and foreign domiciliaries.  Other areas of practice include prosecution of tax crime in complex cases, particularly along the avoidance/evasion faultline, and freedom of information.

James is one of the founders of the Society of Trust and Estate Practitioners, for whom he drafted the STEP Standard Provisions, and a fellow of the Chartered Institute of Taxation. James has received the Geoffrey Shindler Award for Outstanding Contribution to the Profession.

Etienne Wong qualified as a solicitor in 1990, and was a partner and head of the international VAT unit at Clifford Chance LLP from 1999 to 2014.  He was called to the Bar in 2014.  He has been advising on all aspects of VAT since 1989, with a primary focus on exemptions, VAT recovery and whether transactions are in scope for, or outside the scope of, VAT - issues of particular pertinence to charities.”  

Mary Ashley is a barrister practicing from Old Square Tax Chambers and was called to the Bar in 2014. She advises on all areas of tax law in particular inheritance tax, stamp duty land tax, charities tax and all aspects of trusts. She graduated from Keble College, Oxford University where she subsequently completed the BCL. She currently sits on the Board for the Association of Women Barristers. 

They can be instructed through their clerks by email at  



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. Companies held by Charities

10. Business Sponsorship and Advertising

11. Charitable Companies

12. Employees and Beneficiaries of Charities

13. Acquisition of Companies

14. Double Taxation Treaties and Charities

15. Cash Gifts from Individual to Charity (Gift Aid)

16. Gift Aid Small Donations Scheme

17. Corporate Gift Aid

18. Giving by Businesses to Charity

19. Payroll Giving

20. Interest-free Loans to Charity

21. Gifts of Shares and Land to Charity

22. 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 Gifts 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. VAT: Basic Concepts

36. Recovery of Input VAT

37. VAT: Exemption

38. VAT: Zero Rating

39. Stamp Duties

40. Rating Relief

41. Community Amateur Sports Clubs

42. Political parties

43. Housing Associations

44. Local Authorities

45. Social Investment Relief

46. Administration: Tax returns and claims


Appendix 1: International Entity Securities: Approved Charitable Investments.

Appendix 2: HMRC Model Gift Aid Declarations

Appendix 3: Retail Gift Aid: Template Letters

Appendix 4: CASCs: Eligible Sports

Appendix 5: Deemed Charities and National Bodies

Appendix 6: Accreditation of Social Impact Contractors

Appendix 7: Substantial Donor Rules

Appendix 8: How to Improve the Taxation of Charities

Appendix 9: Bibliography