Decision

Advice letter: Luke Hall, Chief Executive Officer, Charity Tax Group

Updated 9 December 2025

1. BUSINESS APPOINTMENT APPLICATION: Luke Hall, former Minister of State for Skills, Apprenticeships and Higher Education, Department for Education – Chief Executive Officer, Charity Tax Group

Thank you for your application, under the Government’s Business Appointment Rules for Former Ministers (the Rules), for my advice on joining Charity Tax Group as Chief Executive Officer.

The purpose of the Rules, as you will be aware, is to protect the integrity of government and to avoid any suspicion that those who have served in government might profit improperly from that experience or that an employer might gain unfair advantage through privileged access to government. To achieve these aims, I designate conditions that former ministers must follow.

The material information and my consideration are set out in the annex. In light of this, I consider the following conditions to be appropriate, recognising that it is your responsibility to ensure that these are demonstrably applied in practice:

• Privileged information condition – You should not draw on (disclose or use for the benefit of Charity Tax Group consultancy, related parties and clients) any privileged information available to you from your time in ministerial office. This is an ongoing duty irrespective of the time elapsed since you left office.

• Lobbying condition – For two years from your last day in office, you should not become personally involved in lobbying the UK Government or its arm’s length bodies on behalf of Charity Tax Group consultancy (including related parties and clients); nor should you make use, directly or indirectly, of your contacts in the government and/or ministerial office to influence policy, secure business/funding or otherwise unfairly advantage Charity Tax Group (including related parties and clients).

• Contracts and bids condition – For two years from your last day in office, you should not undertake any work with Charity Tax Group (including related parties and clients) that involves providing advice on the terms of, or with regard to the subject matter of a bid with, or contract relating directly to the work of, the UK Government or its arm’s length bodies.

• Business development restriction – For two years from your last day in office, you should not, for the purpose of securing business for Charity Tax Group (including its related parties and clients), lobby contacts you acquired during your time in office, in other organisations, including other governments.

I would be grateful if you would note the following points:

• My advice is not an endorsement of the appointment.

• The advice relates solely to your previous role in government; it is separate from rules administered by other bodies such as the Office of the Registrar of Consultant Lobbyists, the Parliamentary Commissioner for Standards and the Registrar of Lords’ Interests. It is your personal responsibility to understand any other rules and regulations you may be subject to in parallel with my advice.

• By ‘privileged information’, I mean official information to which you had access as a consequence of holding office and which is not publicly available. You are also reminded that you may be subject to other duties of confidentiality, whether under the Official Secrets Act, the Ministerial Code or otherwise.

• As set out in the Rules, the lobbying restriction means that former ministers ‘should not engage in communication with government (ministers, civil servants, including special advisers, and other relevant officials/public office holders) –wherever it takes place – with a view to influencing a government decision, policy or contract award/grant in relation to their own interests or the interests of the organisation by which they are employed, or to whom they are contracted or with which they hold office’.

As soon as you take up the appointment, or if it is announced that you will do so, you are obliged under the Rules to inform my secretariat who will then publish this letter. You must also inform us if you propose to extend or otherwise change the nature of your role as, depending on the circumstances, it may be necessary for you to make a fresh application.

Yours sincerely,

Sir Laurie Magnus CBE

Independent Adviser on Ministerial Standards

2. Annex – Material information and consideration of the risks

2.1 The role

You wish to take up a paid, part-time role as Chief Executive Officer (CEO), Charity Tax Group (CTG), a registered charity providing technical expertise on all charity tax matters, guidance and practical support to help charities reduce their tax burdens and a platform for charities and others stakeholders’ discussion of challenges and issues regarding charity tax.

In your role as CEO, you will:

• help establish a vision and operational plan for CTG’s future

• lead on fundraising and income diversification to ensure financial sustainability

• contribute to sector press and events

• work with Technical Advisors to sustain CTG’s authority and expertise

• bring interested parties together to talk about charity tax developments and changes

• share timely and relevant insight into charity tax news and development through

bulletins, newsletters, online meetings, webinars and events

• act as CTG spokesperson with government, charities and the media

• enable members and the wider charity sector to be heard

• ensure provision of online resources to help charities navigate the tax system.

You stated that the role would involve contact with central government on CTG’s behalf. You noted that CTG interacts with the UK Government in two key areas:

• with HMRC, conducted by external tax experts at a technical level – an approach that will remain in place;

• in the form of submissions to HMT’s annual Budget process.

2.2 Departmental assessment

The Department for Education confirmed that, in your short period in office, you were neither involved in regulatory or policy decisions nor had access to sensitive information that may provide an unfair advantage to CTG. The department recommended that the standard conditions apply to the appointment.

2.3 My consideration of the risks

The risks relating to your involvement in policy, regulatory or commercial decisions specific to CTG are limited because:

• you were in office for a short period (26 March to 5 July 2024)

• you made few decisions during this time and held a remit with minimal overlap with CTG’s area of work

• DfE had no concerns over your access to privileged information.

You will be CTG’s sole employee in a role to act as ‘spokesperson’ including in relation to the Government. In considering the risk that you may be perceived as lobbying the Government on CTG’s behalf, I have noted that CTG is a charitable organisation with no commercial focus and not competing with others in its area of operation; it has an existing framework for its main interactions with the UK Government, namely with HMRC at a technical level using external tax experts, an approach that will be maintained after your appointment; CTG’s other interactions in the form of submissions to HM Treasury’s annual Budget process form part of a government-led exercise which actively solicits submissions and therefore does not constitute lobbying under the Rules. I also consider it of significant relevance that CTG has provided written confirmation of its agreement to comply with the advice and of the separation of your role from lobbying. These factors, alongside the brevity of your tenure as minister with little overlap with CTG’s area of work, significantly limit the risk of a reasonable perception that you are being appointed to influence the Government on the organisation’s behalf.

Your role with CTG includes responsibility for fundraising and income diversification. In respect of contacts in other governments and organisations acquired only as a result of your role as a minister, there is therefore a risk you could be seen to advantage CTG unfairly by drawing on such contacts on its behalf to secure funds or opportunities for new income streams. I have therefore applied a restriction to prevent you from lobbying these contacts for the purpose of fundraising or prospecting for new income streams for CTG.