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HMRC internal manual

Company Taxation Manual

Corporation Tax: management expenses: employees seconded to charities


An investment company (or, for periods starting on or after 1 April 2004, a ‘company with investment business’) may make available the services of an employee to a charity (or to certain educational establishments) on a temporary basis. In such a case the expenditure on the remuneration and related costs of the employee may still qualify as an expense of management. There is relief under ICTA88/S86 for expenditure attributable to the employment. There is guidance on employees seconded to charities at BIM47115 and to educational establishments at BIM47120.