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HMRC internal manual

Employment Income Manual

Ministers of religion: exemption of income: overview

Section 290 ITEPA 2003 and Extra-Statutory Concession A61

Some ministers are exempted from liability on certain types of income connected with their occupation of property. Those qualifying are ministers who:

  • are provided with a residence from which they are expected to perform their duties and
  • hold a full-time office as a minister.

This special treatment only applies where some legal interest in the residence belongs to either a charity or an ecclesiastical corporation. So, for example, premises belonging to a Diocesan Board of Finance, a Cathedral Chapter, a body of trustees acting for a denomination or for a local congregation, and a parochial church council, are all covered. It also covers parsonage houses vested in incumbents of benefices in the Church of England (see Mitchell v Child (24TC511)).

For examples of properties that do not meet the requirements for exemption see EIM60009.

For the type of income that is exempt from charge see EIM60011.

If a claim to benefit from the special rules is pressed but you are doubtful whether the claimant can be regarded as a minister, consult PAYE Technical.(This content has been withheld because of exemptions in the Freedom of Information Act 2000)