The Association of Charitable Foundations (ACF) has recently published two key clarifications that it received from HMRC on its Common Reporting Standard (CRS) guidance for charities:

• The first had been shared with CTG as a member of the Charity Tax Forum, but had not been made available in public guidance. It confirms that while a UK incorporated charity may qualify as a financial institution, it will not have to carry out due diligence or report on grant holders and will only be required to do so for members of the company who have a debt or equity interest.
• The second highlights that Unit Trusts are not regarded as being investments under ‘discretionary management’. This means that trusts or foundations that have placed all of their investments in unit trusts will not be caught by CRS. The reason is that in such cases, HMRC regards the charity as essentially taking a share the profits of the unit trust rather than investing into the market directly.

For more information on the CRS, click here. A useful commentary containing ten top tips for charities was also recently published.