Consultations update – November 2018

Responding to relevant Government and sectoral consultations is one of CTG’s core functions and is only possible with the support and feedback from member charity and advisers. Consultation responses are often combined with direct lobbying of Ministers and officials and require significant time and resource commitments, but we know that this is a priority for members.

We are pleased that a number of recent CTG consultation responses have helped to influence positive announcements for the sector and will hopefully save charities time and money. This includes the relaxation or extension of existing rules and thresholds, as well as instances where existing tax reliefs and exemptions have been defended. A summary of recent formal consultations is outlined below:

Consultation closed and response published

  • Budget 2018 (HM Treasury): CTG made a pre-Budget submission on 28 September 2018, including calls for changes to rules relating to GASDS, retail Gift Aid and the small trading exemption. The Budget was published on 29 October 2018, accepting each of these proposals. A summary of the key announcements can be found here.
  • Reforming the Community Infrastructure Levy (MHCLG): CTG response submitted on 10 May 2018. The Government response, published in October 2018, confirmed that the charity exemption be maintained, something CTG called for in its response. Read more here.
  • VAT registration threshold (HMRC): CTG response submitted on 5 June 2018. The Government’s response to the consultation confirms that due to a lack of consensus on reform, the current VAT threshold will be maintained until April 2022. this will be reviewed once the terms of EU exit are clear. CTG has welcomed this news as had there been a decrease in the VAT threshold additional smaller charities would potentially have been subject to MTD reporting requirements, which are already proving complex for larger charities. Read more here.
  • Tackling Avoidance of Non-Domestic Rates in Wales (Welsh Government): CTG response submitted on 27 June 2018 recognising the need to tackle avoidance but calling on the action taken to be proportionate and targeted. The Welsh Government response took on board the concerns of the sector did not at this stage, propose making any changes to the arrangements for mandatory and discretionary charitable relief in this context.  Read more here.
  • Off-payroll working (HMRC): CTG response submitted on 17 August 2018 calling for support for charities and a staggered implementation. The Government response, published on 29 October confirmed the extension of off-payroll working (IR35 rules) to the private sector but not until April 2020, with small organisations to be exempt. Read more here.

 Consultation closed and awaiting response

  •  VAT inquiry (Treasury Committee): CTG response submitted on 31 May 2018, including representations on Making Tax Digital, Business/Non-Business, VAT registration and obstacles for charities caused by the VAT system. Committee response awaited.
  • IHT Review (OTS): CTG response submitted on 7 June 2018, highlighting the value of the relief as an option for donors and calling for improved communications about the relief to help increase take-up. OTS response expected in the next few weeks
  • Charity Tax Commission Call for Evidence (NCVO): CTG response submitted on 6 July 2018.  Commissioners expected to respond in early 2019.
  • Implementation of non-domestic rates reform following proposals by the Barclay Review (Scottish Government): closed on 17 September 2018. CTG did not respond but will monitor developments closely. No indication when the Scottish Government will respond.

 Open consultations

  •  SDLT regulation (HMRC): responses to the consultation due by 23 November 2018.
  • Taxation of trusts (HMRC): responses to the consultation due by 30 January 2019.
  • Gift Aid and intermediaries fees (JustGiving): JustGiving will be consulting charities at the next Gift Aid working group meeting in December