The University is subject to Corporation Tax on non-primary purpose activity, and there is guidance and training available to assist in distinguishing non-primary purpose activities from primary purpose.
A primary purpose ‘activity’ is one that furthers the charitable objects of the University. University Statute I, paragraph 3 provides:
“The principal objects of the University are the advancement of learning by teaching and research and its dissemination by every means.”
In addition to this, a charity’s primary purpose activities must also provide public benefit as defined by the Charity Commission.
Therefore, a primary purpose activity must both:
- have a charitable purpose.
‘Advancement of education’ is a charitable purpose set out in the Charities Act.
- be for public benefit – all the following must apply:
- there must be an identifiable benefit;
- benefit must be to the public or a section of the public;
- people on low incomes must be able to benefit; and
- any private benefit must be incidental.