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HMRC internal manual

Employment Income Manual

Tax treatment of collegiate bodies

Collegiate body admitted as a charity

Where a collegiate body has been admitted as a charity (see RE2100 onwards), stipends, salaries, etc. paid to members and officers of the collegiate body are taxable as employment income. This applies whether or not the stipends, salaries, etc. are charged by statute on the income of the body.

Collegiate body not admitted as a charity

Where a collegiate body has not been admitted as a charity, the sums that the members are entitled to receive out of the income of the body and such salaries of officers that by statute constitute a charge on that income, are regarded as taxed by deduction. The treatment of any such sums for tax purposes depends on the terms of the constitution of the body.

Further guidance

Refer to HMRC Charities, or HMRC Trusts (Edinburgh) for Scottish cases, any case for which directions have not been received. Any salaries that do not constitute a charge on the income of the body are chargeable to tax as employment income (Langston v Glasson (3TC46)).