Commentary

B5.830 Charity exemption for property income

Business tax
Business tax | Commentary

B5.830 Charity exemption for property income

Business tax | Commentary

B5.830 Charity exemption for property income

No account is taken, in calculating total income, of income that is chargeable to tax as either trading or property income in so far as it arises in respect of rents or other receipts from an estate, interest or right in or over land and the estate and the interest or right is vested in any person in trust for charitable purposes1.

Distributions out of tax-exempt profits of a UK real estate investment trust (REIT) (see Division D7.11) are similarly left out of account.

The exemption only applies in so far as the income is applied to charitable purposes only. See, for example, Trades House of Glasgow v IRC2. This case concerned a fund established for the maintenance of a building in Glasgow designed by Robert Adam. To that extent its purpose was charitable. However, as it also partly relieved a

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