HMRC internal manual

Business Income Manual

BIM62101 - Particular trades: missionaries

Those who carry on missionary or similar work, especially within a religious context (if not employees or office-holders - see the case references below), may receive income from a vocation which is taxable as trading income.

Taxable receipts of the vocation will include any sums received by virtue of the exercise of the vocation, or that enable the missionary or evangelist to continue to exercise the vocation. For example, grants or gifts (whether solicited or not) by religious bodies, charitable trusts or individuals for the maintenance of the individual or their family.

Taxable receipts of the vocation will not include:

  • monies given towards specific works such as the building or repair of a place of worship, in relation to which the individual acts in the capacity of a trustee;
  • personal testimonials, or personal gifts, for example on marriage or civil partnership, or for medical treatment;
  • personal gifts from parents or immediate friends.

For general guidance on voluntary receipts see BIM41800 onwards, and case law authority in:

  • CIR v Falkirk Ice Rink Ltd [1975] 51TC42,
  • Wing v O’Connell [1927] 1ITC170 and
  • Temperley v Smith [1956] 37TC18 (particularly pages 23-24).