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HMRC internal manual

Company Taxation Manual

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HM Revenue & Customs
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Particular bodies: unincorporated associations: part of a wider undertaking?

Whether a particular organisation is part of a wider undertaking or is a separate autonomous association will depend upon the facts, but Conservative and Unionist Central Office v Burrell, (1982) 55TC671 provides guidance.

Here, there was a constitutional gap between the national union and the parliamentary party.  The bond of contract, agreement or understanding which must link the members of an unincorporated association did not exist between the constituency associations and the party.  Thus in this case there was more than one unincorporated association.

Whether a body stands on its own or is part of a larger unincorporated association is significant for such matters as the rate of CT chargeable and roll over relief.