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HMRC internal manual

Business Income Manual

From
HM Revenue & Customs
Updated
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Meaning of trade: mutual trading and members clubs: mutual associations: specific activities: trade protection associations: introduction and layout of guidance

Trade associations are within the charge to Corporation Tax. This is so whether or not they have adopted the HMRC arrangement referred to in BIM24805 onwards.

It is important to recognise from the outset that the HMRC arrangement is only appropriate in those cases where the subscriptions in question are not otherwise chargeable to Corporation Tax - that is to say the activities of the trade protection association do not amount to the carrying on of a trade. Whether activities amount to a trade is essentially a question of fact. There is more on this at BIM24045.

The following pages cover:

BIM24805 HMRC arrangement
   
BIM24810 Procedural points when adopting HMRC arrangement
BIM24815 Benefits to members of adopting the HMRC arrangement
BIM24820 Text of HMRC arrangement