474A Legacies: corporation tax liability and exemption
(1) This section applies to a gift of property—
(a) that is made by will to a charitable company, and
(b) that is not chargeable to corporation tax apart from this section.
(2) The value of the property that is the subject of the gift is treated as an amount in respect of which the charitable company is chargeable to corporation tax, under the charge to corporation tax on income.
(3) For that purpose the value of any property other than money is its market value as at the time of the death of the person by whose will the gift of the property is made.
(4) But the value attributable to property is not taken into account in calculating total profits so far as the property is applied to charitable purposes only.
(5) A gift of property made to a charitable company is treated for the purposes of this section as made by will if—
(a) the gift is made to the company by virtue of the variation, after a person’s death, of a disposition of property effected by the person’s will, and
(b) the variation is treated under section 142 of the Inheritance Tax Act 1984 (alteration of dispositions taking effect on death) has having been effected by the deceased.
(6) The exemption under subsection (4) requires a claim.
(7) In this section—
“property” includes rights and interests of any description;
“will” includes a testament, a codicil and any testamentary disposition of property.
475 Gifts qualifying for gift aid relief: income tax treated as paid and exemption
(1) This section applies if a gift is made to an eligible body by an individual and the gift is a qualifying donation for the purposes of Chapter 2 of Part 8 of ITA 2007 (gift aid).
(2) The eligible body is treated as receiving, under deduction of income tax at the basic rate for the tax year in which the gift is made, a gift of an amount equal to the grossed up amount of the gift.
(3) References in this section to the grossed up amount of the gift are to the amount of the gift grossed up by reference to the basic rate for the tax year in which the gift is made.
(4) The income tax treated as deducted is treated as income tax paid by the eligible body.
(5) The grossed up amount of the gift is not taken into account in calculating total profits.
(6) The exemption under subsection (5) requires a claim.
(7) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(8) In the case of an eligible body which is a charitable company, this section applies instead of sections 471 and 472.
(1) If an eligible body receives a gift of a sum of money from a company, the gift is not taken into account in calculating total profits.
(2) The exemption under subsection (1) requires a claim.
(3) In the case of an eligible body which is a charitable company, this section applies instead of section 473.
(1) A gift of a sum of money that a body receives from a company is not taken into account in calculating total profits if the body receiving the gift qualifies as a scientific research association for the relevant accounting period.
(2) The exemption under subsection (1) requires a claim.
(3) In subsection (1) “the relevant accounting period” means the accounting period for which the exemption is to be claimed.
(4) In the case of a body which qualifies as a scientific research association and is also a charitable company, this section applies instead of section 473.
(A1) This section applies to claims for repayment of income tax treated as having been paid by virtue of—
(a) section 471 (gifts qualifying for gift aid relief: charitable companies), or
(b) section 475 (gifts qualifying for gift aid relief: eligible bodies).
(1) This section also applies to claims for amounts to be exempt from tax by virtue of—
(a) section 472 (gifts qualifying for gift aid relief: charitable companies), or
(b) section 475 (gifts qualifying for gift aid relief: eligible bodies).
(2) A claim to which this section applies may be made—
(a) to an officer of Revenue and Customs, or
(b) where the claimant is a company, by being included in the claimant's company tax return.
(3) In this section—
“ free-standing claim ” means a claim made as mentioned in subsection (2)(a), and
“ tax return claim ” means a claim made as mentioned in subsection (2)(b).
(4) The Commissioners for Her Majesty's Revenue and Customs may by regulations make provision—
(a) limiting the number of free-standing claims that may be made by a person in a tax year, or
(b) requiring a claim for an amount below an amount specified in the regulations to be made as a tax return claim.
(5) The regulations may make different provision for different cases or purposes.
478 Exemption for profits etc of charitable trades
(1) The income mentioned in subsection (2) is not taken into account in calculating total profits if the condition in subsection (3) is met.
(2) The income referred to in subsection (1) is—
(a) profits of a charitable trade carried on by a charitable company, and
(b) post-cessation receipts arising from a charitable trade carried on by a charitable company which are received by the company or to which it is entitled.
(3) The condition is that the profits are, or (as the case may be) the post-cessation receipt is, applied to the purposes of the charitable company only.
(4) In this section “post-cessation receipt” means an amount that is a post-cessation receipt for the purposes of Part 3 of CTA 2009 (see sections 190 to 195 of that Act).
(5) The exemption under subsection (1) requires a claim.
(1) For the purposes of this Part a trade carried on by a charitable company is a charitable trade if—
(a) the trade is exercised in the course of carrying out a primary purpose of the charitable company, or
(b) the work in connection with the trade is mainly carried out by beneficiaries of the charitable company.
(2) For the purposes of subsection (1)(a), if a trade is exercised partly in the course of carrying out a primary purpose of the charitable company and partly otherwise, each part is to be treated as a separate trade.
(3) For the purposes of subsection (1)(b), if work in connection with a trade is carried out partly but not mainly by beneficiaries, the part in connection with which work is carried out by beneficiaries and the other part are to be treated as separate trades.
(4) If different parts of a trade are treated as separate trades under subsection (2) or (3), a just and reasonable apportionment is to be made for that purpose of—
(a) expenses and receipts of the trade, and
(b) any amounts which are post-cessation receipts arising from the trade for the purposes of Part 3 of CTA 2009.
(1) The income mentioned in subsection (2) is not taken into account in calculating total profits if conditions A and B are met.
(2) The income referred to in subsection (1) is—
(a) the profits of a trade carried on by a charitable company, and
(b) post-cessation receipts arising from a trade carried on by a charitable company which are received by the company or to which it is entitled.
(3) Subsection (1) does not apply in respect of—
(a) profits of a trade that are, apart from this section, exempt from corporation tax chargeable under Part 3 of CTA 2009, or
(b) post-cessation receipts that are, apart from this section, exempt from corporation tax chargeable under Chapter 15 of Part 3 of CTA 2009.
(4) Condition A is—
(a) in the case of the profits of a trade, that the profits are profits of an accounting period in relation to which the condition specified in section 482 (condition as to trading and miscellaneous incoming resources) is met, and
(b) in the case of a post-cessation receipt, that it is received in such an accounting period.
(5) Condition B is that the profits are, or (as the case may be) the receipt is, applied to the purposes of the charitable company only.
(6) The exemption under subsection (1) requires a claim.
(7) In this section “post-cessation receipt” means an amount that is a post-cessation receipt for the purposes of Part 3 of CTA 2009 (see sections 190 to 195 of that Act).
481 Exemption from charges under provisions to which section 1173 applies
(1) Any income or gains of a charitable company that is or are chargeable to corporation tax under or by virtue of any provision to which section 1173 applies is not or are not taken into account in calculating total profits if conditions A and B are met.
(2) Subsection (1) does not apply in respect of any income or gains that is or are chargeable to corporation tax by virtue of any of—
(a) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(b) section 1086(2) (chargeable payments connected with exempt distributions), and
(c) any other enactment specified in an order made by the Treasury.
(3) Subsection (1) does not apply in respect of any income that is, or gains that are, apart from this section, exempt from corporation tax chargeable under or by virtue of any provision to which section 1173 applies.
(4) Condition A is that the income is, or the gains are, for an accounting period in relation to which the condition specified in section 482 (condition as to trading and miscellaneous incoming resources) is met.
(5) Condition B is that the income is, or the gains are, applied to the purposes of the charitable company only.
(6) The exemption under subsection (1) requires a claim.
482 Condition as to trading and miscellaneous incoming resources
(1) The condition in this section is met in relation to an accounting period if—
(a) the sum of the charitable company's trading incoming resources and miscellaneous incoming resources for the accounting period does not exceed the requisite limit for the period, or
(b) the charitable company had, at the beginning of the period, a reasonable expectation that it would not do so.
(2) The charitable company's “trading incoming resources” for the accounting period are—
(a) the incoming resources which are required to be taken into account in calculating the profits of, or losses made in, the period for any non-exempt trade carried on by the company, and
(b) the incoming resources which are post-cessation receipts arising from such a trade.
“Post-cessation receipt” has the meaning given by section 480(7).
(3) For the purposes of subsection (2) a trade is a “non-exempt trade” if any profits of the trade would not, apart from section 480, be exempt from corporation tax chargeable under Part 3 of CTA 2009.
(4) The charitable company's “miscellaneous incoming resources” for the accounting period are the incoming resources which are required to be taken into account in calculating non-exempt miscellaneous income or non-exempt miscellaneous losses for the period.
(5) In subsection (4)—
“non-exempt miscellaneous income” means income or gains chargeable to corporation tax under or by virtue of any provision to which section 1173 applies that is not, or are not, apart from section 480 or 481, exempt from corporation tax chargeable under or by virtue of that provision, and
“non-exempt miscellaneous losses” means losses arising from a transaction which is of such a nature that if income or gains had arisen from it the income would have been non-exempt miscellaneous income.
(6) The requisite limit—
(a) is 25% of the charitable company's total incoming resources for the accounting period, but
(b) must not be less than £8,000 or more than £80,000.
(7) If the accounting period is shorter than 12 months, the amounts of £8,000 and £80,000 mentioned in subsection (6)(b) are proportionately reduced.
483 Exemption for profits from fund-raising events
(1) The profits of a trade carried on by a charitable company are not taken into account in calculating total profits so far as they—
(a) arise from an event that is VAT-exempt in relation to the company, and
(b) are applied to charitable purposes or transferred to a charity.
(2) The profits of a trade carried on by a body to which subsection (3) applies are not taken into account in calculating total profits so far as they—
(a) arise from an event that is VAT-exempt in relation to the body, and
(b) are applied to charitable purposes or transferred to a charity.
(3) This subsection applies to any voluntary organisation that is a qualifying body for the purposes of Group 12 of Schedule 9 to the Value Added Tax Act 1994 (fund-raising events by charities and other qualifying bodies).
(4) The exemptions under this section require a claim.
(5) For the purposes of this section an event is VAT-exempt in relation to a person if the supply of goods and services by that person in connection with the event would be exempt from value added tax under Group 12 of Schedule 9 to the Value Added Tax Act 1994.
(1) The profits accruing to a charitable company from a lottery are not taken into account in calculating total profits if conditions A and B are met.
(2) Condition A is that—
(a) the lottery is an exempt lottery within the meaning of the Gambling Act 2005 by virtue of Part 1 or 4 of Schedule 11 to that Act,
(b) the lottery is promoted in accordance with a lottery operating licence within the meaning of Part 5 of the Gambling Act 2005, or
(c) the lottery is promoted and conducted in accordance with Article 133 or 135 of the Betting, Gaming, Lotteries and Amusements (Northern Ireland) Order 1985 (S.I. 1985/1204 (N.I. 11)).
(3) Condition B is that the profits are applied to the purposes of the charitable company only.
(4) The exemption under subsection (1) requires a claim.
(1) Income which is chargeable to corporation tax under Part 3 of CTA 2009 (trading income) as a result of section 287 of that Act is not taken into account in calculating total profits so far as—
(a) it arises in respect of rents or other receipts from an estate, interest or right in or over land, and
(b) the estate, interest or right is vested in any person for charitable purposes.
(2) Income which is chargeable to corporation tax under Part 4 of CTA 2009 (property income) is not taken into account in calculating total profits so far as—
(a) it arises in respect of an estate, interest or right in or over land, and
(b) the estate, interest or right is vested in any person for charitable purposes.
(3) Distributions to which section 548 (Real Estate Investment Trusts: distributions) applies and which are chargeable to corporation tax under Part 4 of CTA 2009 are not taken into account in calculating total profits so far as they arise in respect of shares vested in any person for charitable purposes.
(4) Subsections (1) to (3) apply so far as the income is applied to charitable purposes only.
(5) The exemptions under this section require a claim.
486 Exemption for investment income and non-trading profits from loan relationships
(1) The income mentioned in subsection (2) is not taken into account in calculating total profits if—
(a) it is income of a charitable company, or
(b) it is required, under an Act (including an Act of the Scottish Parliament), court judgment, charter, trust deed or will, to be applied to charitable purposes only.
(2) The income referred to in subsection (1) is—
(a) profits which are charged to tax under section 299 of CTA 2009 (non-trading profits from loan relationships),
(b) a dividend or other distribution of a company, and
(c) income treated for the purposes of regulation 15 of the Unauthorised Unit Trusts (Tax) Regulations 2013 as received by a unit holder from an exempt unauthorised unit trust.
(3) Subsection (1) applies, in relation to the income mentioned in subsection (2)(b), only so far as the income falls within, and is dealt with under, Part 9A of CTA 2009 (see section 931W of that Act as to provisions given priority over Part 9A).
(4) Subsection (1) applies, in relation to the income mentioned in subsection (2)(c), only so far as the income falls within, and is dealt with under, regulation 15 of the Unauthorised Unit Trusts (Tax) Regulations 2013 (see regulation 17 of those regulations as to provisions given priority over that regulation).
(5) Subsection (1) applies so far as the income is applied to charitable purposes only.
(6) The exemption under subsection (1) requires a claim.
(1) Public revenue dividends on securities which are in the name of trustees are not taken into account in calculating total profits so far as the dividends are applicable and applied only for the repair of—
(a) a cathedral, college, church or chapel, or
(b) a building used only for the purposes of divine worship.
(2) In this section “public revenue dividends” means—
(a) income from securities which is payable out of the public revenue of the United Kingdom or Northern Ireland, or
(b) income from securities issued by or on behalf of a government or a public or local authority in a country outside the United Kingdom.
(3) The exemption under subsection (1) requires a claim.
(1) The income mentioned in subsection (3) is not taken into account in calculating total profits if—
(a) it is income of a charitable company, or
(b) it is required, under an Act (including an Act of the Scottish Parliament), court judgment, charter, trust deed or will, to be applied to charitable purposes only.
(2) Subsection (1) applies so far as the income is applied to charitable purposes only.
(3) The income referred to in subsection (1) is—
(a) non-trading gains on intangible fixed assets,
(b) annual payments charged to tax under Chapter 7 of Part 10 of CTA 2009, and
(c) qualifying income from intangible fixed assets.
(4) The exemption under subsection (1) requires a claim.
(5) In this section—
“intangible fixed asset” has the same meaning as in Part 8 of CTA 2009 (see section 713 of that Act),
“non-trading credit” has the meaning given by section 301 of CTA 2009,
“non-trading gain” has the meaning given by section 751 of CTA 2009,
“pre-FA 2002 asset” has the meaning given by sections 881 and 892 to 895 of CTA 2009, and
“qualifying income from intangible fixed assets” means income which—
is in respect of intangible fixed assets which are pre-FA 2002 assets,
is of a kind which, if the intangible fixed assets were not pre-FA 2002 assets, would fall to be brought into account under Chapter 6 of Part 8 of CTA 2009 as non-trading credits, and
does not fall within subsection (3)(a) or (b).
489 Exemption for income from estates in administration
(1) If a charitable company is liable for any corporation tax charged under section 934 of CTA 2009 (charge to tax on estate income), the estate income is not taken into account in calculating total profits.
(2) Subsection (1) applies so far as the estate income is applied to the purposes of the charitable company only.
(3) The exemption under subsection (1) requires a claim.
(4) In this section “estate income” has the same meaning as in Chapter 3 of Part 10 of CTA 2009 (see section 934 of that Act).
(1) The provisions mentioned in subsection (3) apply in relation to an eligible body as they apply in relation to a charitable company.
(2) But in relation to an eligible body those provisions have effect as if the whole income of the body were applied to charitable purposes.
(3) The provisions referred to in subsection (1) are—
(a) sections 478 and 479 (profits of charitable trades),
(b) section 483 (profits from fund-raising events),
(c) section 484 (profits from lotteries),
(d) section 485 (property income etc),
(e) section 486 (investment income etc),
(f) section 488 (certain miscellaneous income), and
(g) section 489 (income from estates in administration).
(1) The provisions mentioned in subsection (3) (which confer exemptions) apply in relation to a body which qualifies as a scientific research association for the relevant accounting period as they apply in relation to a charitable company.
(2) But in relation to such a body those provisions have effect as if the whole income of the body were applied to charitable purposes.
(3) The provisions referred to in subsection (1) are—
(a) sections 478 and 479 (profits of charitable trades),
(b) section 483 (profits from fund-raising events),
(c) section 484 (profits from lotteries),
(d) section 485 (property income etc),
(e) section 486 (investment income etc),
(f) section 488 (certain miscellaneous income), and
(g) section 489 (income from estates in administration).
(4) In subsection (1) “the relevant accounting period” means the accounting period for which the exemption in question is to be claimed.
(1) Subsections (2) to (5) of section 477A (claims in relation to gift aid relief) apply to—
(a) claims for amounts to be exempt from tax by virtue of a provision listed in subsection (2), and
(b) claims for repayment of income tax deducted at source from income which is exempt from tax by virtue of such a provision,
as they apply to claims to which that section applies.
(2) The provisions are—
(a) section 486 (investment income and non-trading profits from loan relationships),
(b) section 487 (public revenue dividends),
(c) section 488 (certain miscellaneous income), and
(d) section 489 (income from estates in administration).
(1) This section applies if a charitable company has a non-exempt amount for an accounting period (see section 493).
(2) The exemptions mentioned in subsection (3) do not apply, and are treated as never having applied, to so much of any income of the charitable company for the accounting period as is attributed under section 494 to the non-exempt amount.
(3) Those exemptions are—
(a) the exemptions under this Part, and
(b) the exemption under regulation 31(1) of the Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001) (exemption from corporation tax in respect of certain offshore income gains).
(4) Section 256(4) of TCGA 1992 contains corresponding restrictions which apply in relation to section 256(1) of that Act (gains accruing to charities not to be chargeable gains).
(1) A charitable company has a non-exempt amount for an accounting period if it has—
(a) non-charitable expenditure for the period (amount A), and
(b) attributable income and gains for the period (amount B).
(2) The non-exempt amount for the accounting period is—
(a) amount A, or
(b) if less, amount B.
(3) For the purposes of this Part—
(a) a charitable company's “attributable income” for an accounting period is the charitable company's income for the period that is exempt from corporation tax as a result of any of the exemptions mentioned in section 492(3),
(b) a charitable company's “attributable gains” for an accounting period are any gains accruing to the charitable company in the period that as a result of section 256(1) of TCGA 1992 are not chargeable gains, and
(c) a charitable company's “attributable income and gains” for an accounting period is the sum of its attributable income for the period and its attributable gains for the period.
(4) In applying subsection (3)(a) ignore any restrictions on the exemptions under this Part which result from section 492(2).
(5) In applying subsection (3)(b) ignore any restriction on the exemption under section 256(1) of TCGA 1992 which results from section 256(4) of that Act.
(1) This section applies if a charitable company has a non-exempt amount for an accounting period.
(2) Attributable income of the charitable company for the accounting period may be attributed to the non-exempt amount but only so far as the non-exempt amount has not been used up.
(3) The non-exempt amount can be used up (in whole or in part) by—
(a) attributable income being attributed to it under this section, or
(b) attributable gains being attributed to it under section 256C of TCGA 1992.
(4) The whole of the non-exempt amount must be used up by—
(a) attributable income being attributed to the whole of it under this section,
(b) attributable gains being attributed to the whole of it under section 256C of TCGA 1992, or
(c) a combination of attributable income being attributed to some of it under this section and attributable gains being attributed to the rest of it under section 256C of TCGA 1992.
495 How income is attributed to the non-exempt amount
(1) This section is about the ways in which attributable income can be attributed to a non-exempt amount under section 494.
(2) The charitable company may specify the attributable income that is to be attributed to the non-exempt amount.
(3) A specification under subsection (2) is made by notice to an officer of Revenue and Customs.
(4) Subsection (6) applies if—
(a) an officer of Revenue and Customs requires a charitable company to make a specification under this section, and
(b) the charitable company has not given notice under subsection (3) of the specification before the end of the required period.
(5) The required period is 30 days beginning with the day on which the officer made the requirement.
(6) An officer of Revenue and Customs may determine the attributable income that is to be attributed to the non-exempt amount.
(1) For the purposes of this Part a charitable company's non-charitable expenditure for an accounting period is—
(a) any loss made in the accounting period in a trade carried on by the charitable company unless—
(i) the trade is a charitable trade, or
(ii) the trade is not a charitable trade but profits of the trade arising in the period would be exempt from corporation tax as a result of one of the exemptions in section 480, 483 or 484,
(b) any loss made in the accounting period in a trade, or in a UK property business or an overseas property business, carried on by the charitable company, if—
(i) the loss relates to land, and
(ii) profits of the trade, or income of the business, generated from the land in the period would not be exempt from corporation tax as a result of the exemptions in section 485,
(c) any loss made in the accounting period in a miscellaneous transaction entered into by the charitable company otherwise than in the course of carrying out a charitable purpose,
(d) any expenditure incurred by the charitable company in the accounting period which is not incurred for charitable purposes only and is not required to be taken into account in calculating—
(i) the profits of, or losses made in, any trade, UK property business or overseas property business carried on by the charitable company, or
(ii) the profit or loss made in any miscellaneous transaction entered into by the charitable company,
(e) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(f) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(g) the amount of any of the charitable company's funds that is invested in the accounting period in an investment which is not an approved charitable investment (see section 511), and
(h) any amount lent in the accounting period by the charitable company, if the loan is neither an investment nor an approved charitable loan (see section 514).
But anything which falls within more than one of the above paragraphs counts as non-charitable expenditure only once.
(2) An amount may also be non-charitable expenditure for an accounting period as a result of section 515 (excess expenditure treated as non-charitable expenditure of earlier periods).
(3) This section needs to be read with—
section 479 (meaning of “charitable trade”),
sections 497 to 501 (supplementary provision in relation to this section, in particular in relation to subsection (1)(d), (g) and (h)),
sections 502 to 510 (transactions with substantial donors),
section 511 (approved charitable investments), and
section 514 (approved charitable loans).
(1) This section applies for the purposes of section 496.
(2) A transaction is a miscellaneous transaction if it is of such a nature that, if income or gains had arisen from it (ignoring section 481 (exemption from charges under provisions to which section 1173 applies)), it would have been charged to corporation tax under or by virtue of any provision to which section 1173 applies.
(3) For rules about the calculation of losses, see—
(a) section 47 of CTA 2009 (losses of a trade calculated on same basis as profits),
(b) section 210 of that Act (which applies section 47 of that Act, so that losses of a UK property business or overseas property business are calculated on the same basis as profits), and
(c) section 1306 of that Act (losses from miscellaneous transactions calculated on same basis as miscellaneous income).
(1) For the purposes of section 496(1)(d) “expenditure” includes expenditure of a capital nature.
(2) None of the following is “expenditure” for those purposes—
(a) the investment of any of the charitable company's funds,
(b) the making of a loan by the charitable company, or
(c) the repayment by the charitable company of the whole or a part of a loan made to it.
499 Section 496(1)(d): accounting period in which certain expenditure treated as incurred
(1) This section applies for the purposes of section 496(1)(d).
(2) Subsection (3) applies to expenditure which is referable to commitments (whether or not of a contractual nature) that the charitable company has entered into before or during an accounting period.
(3) The expenditure is treated as incurred in the accounting period if, had the charitable company been required to draw up accounts that met the requirements mentioned in subsection (4), the expenditure would have been required to be taken into account in preparing those accounts.
(4) The requirements referred to in subsection (3) are—
(a) that the accounts are drawn up for the accounting period, and
(b) that UK generally accepted accounting practice applies with respect to them.
500 Section 496(1)(d): payment to body outside the UK
A payment made, or to be made, to a body situated outside the United Kingdom is non-charitable expenditure under section 496(1)(d) if—
(a) it is incurred for charitable purposes only, but
(b) the charitable company has not taken such steps as the Commissioners for Her Majesty's Revenue and Customs consider are reasonable in the circumstances to ensure that the payment will be applied for charitable purposes.
501 Section 496(1)(g) and (h): investments and loans
(1) Subsection (2) applies if in an accounting period a charitable company—
(a) realises the whole or part of an investment which was made in the period and is not an approved charitable investment (see section 511), or
(b) is repaid the whole or part of a loan which was made in the period and is neither an investment nor an approved charitable loan (see section 514).
(2) Any further investment or lending in the accounting period of the sum realised or repaid, so far as it does not exceed the sum originally invested or lent, is not non-charitable expenditure as a result of section 496(1)(g) or (h).
(1) For the purposes of section 496 “approved charitable investment” means an investment—
(a) that is of a type listed in subsection (2) and is made for an allowable purpose, or
(b) that is not of a type listed in subsection (2) but that is approved under subsection (3).
(2) The following are the types of investment mentioned in subsection (1)(a)—
Type 1
An investment to which section 512 applies.
Type 2
An investment in a common investment fund established under—
section 22 of the Charities Act 1960,
section 24 of the Charities Act 1993,
section 96 of the Charities Act 2011, or
section 25 of the Charities Act (Northern Ireland) 1964.
Type 3
An investment in a common deposit fund established under—
section 22A of the Charities Act 1960, ...
section 25 of the Charities Act 1993. or
section 100 of the Charities Act 2011.
Type 4
An investment in a fund which—
is similar to a fund mentioned in relation to Type 2 or 3, and
is established for the exclusive benefit of charities by or under a provision relating to any particular charities or class of charities contained in an Act (including an Act of the Scottish Parliament).
Type 5
An interest in land, other than an interest held as security for a debt.
Type 6
Any of the following issued by Her Majesty's Government in the United Kingdom—
bills,
Certificates of Tax Deposit,
Savings Certificates, and
Tax Reserve Certificates.
Type 7
Northern Ireland Treasury Bills.
Type 8
Units in a unit trust scheme (as defined in section 237(1) of FISMA 2000) or in a recognised scheme (as defined in section 237(3) of FISMA 2000).“Units” is defined in section 237(2) of FISMA 2000.
Type 9
A deposit with a bank (as defined in section 1120)—
in respect of which interest is payable at a commercial rate, and
which is not made as part of an arrangement under which a loan is made by the bank to some other person.
Type 10
A deposit with—
the National Savings Bank,
a building society, or
a credit institution which operates on mutual principles and which is authorised by an appropriate governmental body in the territory in which the deposit is taken.
Type 11
Certificates of deposit (including uncertificated eligible debt security units as defined in section 986(3) of ITA 2007).
...
(3) An officer of Revenue and Customs may approve a loan or other investment under this subsection if satisfied, on a claim, that it is made for an allowable purpose.
(4) For the purposes of this section an investment is made “for an allowable purpose” if it is reasonable to draw the conclusion, from all the circumstances of the case, that the investment is made—
(a) for the sole purpose of benefiting the charitable company, or
(b) for that purpose and one or more ancillary or incidental purposes,
and is not made for the avoidance of tax (whether by the company or any other person).