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HMRC internal manual

VAT Cost Sharing Exemption Manual

How the conditions are to be interpreted: Some particular forms of Cost Sharing Groups: Can a CSG be a Charity?

To be a charity an organisation must be, among other requirements, established for charitable purposes. So, subject to meeting that test a CSG might be able to be a charity. However, in a charity context a CSG could also be a non-charitable company limited by shares owned by a number of charities and, in practice, this model may be the more likely one. If a CSG was able to acquire charity status there are particular direct tax rules attached to the trading activities of charities that a charity CSG would have to consider, see Charity Direct Tax Guidance (HMRC website ).