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HMRC internal manual

Business Income Manual

Specific deductions: subscriptions: trade associations: HMRC arrangement

A trade association may apply to adopt an arrangement with HMRC, under which:

  • entrance fees, subscriptions, levies and other payments (other than loans or payments of a capital nature) paid by members to the association are allowed in full as deductions,
  • payments by the association to members (other than loans or payments of a capital nature) are treated as trade receipts of members,
  • the association agrees to be chargeable to Corporation Tax on any surplus, computed in accordance with trade profits rules, of its receipts over its expenditure.

In practice, the arrangement normally extends to all subscriptions etc by traders towards the ordinary funds of the association, whether or not the subscribers are members of the association.

Arrangements are not made with associations which are not trade associations (for example, ratepayers’ associations).

For further details on the HMRC arrangement, see BIM24800 onwards.

The names of all associations with which arrangements have been made are available from CTISA (Technical).