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HMRC internal manual

Company Taxation Manual

CTM09510: Relief for expenditure on grassroots sport: background

Before F(2)A17 came into effect payments for the purpose of developing grassroots sport would not generally have been eligible for tax relief as not meeting the test of being incurred ‘wholly and exclusively for the purposes of the trade’ (or equivalent for expenses of management of an investment business), unless developing grassroots sport was the actual trade or business in question.  Exceptions might have been some cases of genuine business-benefitting sponsorship of a sports team or event.

There are, in addition, two specific avenues to obtaining relief:

  • CTA10/S189 allows sports bodies registered as charities to receive payments that can be deducted against the donating company’s CT liability.
  • CTA10/S202 (aa) – ‘registered clubs’ – allows payments made to Community Amateur Sports Clubs (CASCs, see CTM40141) to be deducted for CT in the same way as payments to a charitable body.

CTA10/PART6A provides a further route by which contributions towards grassroots sports can be deducted for CT. This allows qualifying expenditure on grassroots sports as a deduction from the company’s total profits in calculating the CT chargeable for an accounting period.

CTA10/PART6A operates on a similar basis to the existing rules for deductions against total company profits for charitable donations in CTA10/PART6.  Relief under CTA10/PART6A is only available for qualifying expenditure that does not meet the criteria for relief under existing rules.