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Charitable Incorporated Organisations - Group

How much is possible

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There's currently a charitable trust, which owns a facility which is used by a CIO (amongst other users). The CIO (and other corporate users) pay the charitable trust for the privelige.

The trustees of the both the Trust and the CIO wish to create a more manageable and robust structure. I'm struggling to find information regarding what can be done though. The facility will also, in the future, generate advertising revenue (taxable).

I'm aware that a non-charitable company can be a subsidiary of a CIO (a handy proposition since the facility could be moved into a subsidiary company, that company receive the taxable rents, and then donate the rents to the charity, creating a CT deduction and fully mitigating corporation tax). However, can a CIO also have CIO subsidiaries?

The initial thought it is to create a holding entity (either company or CIO), have the asset holding company as a subsidiary, and two CIOs as additional subsidiaries, one to carry out the activities of the existing charitable trust, and one to conduct the activities of the existing CIO.

Could anyone point me to a resource that tells me what is and is not possible in this regard?

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By WhichTyler
18th May 2019 13:42

Too many entities for my taste

why not put the asset into the cio (as opertingor investment asset), wind up the trust and set up a trading subsidiary to the cio for any non-primary purpose trading?

The 'resource' you need is a solicitor familiar with charity law

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Replying to WhichTyler:
By WhichTyler
18th May 2019 15:06

Also worth reading the latest charity commission guidance about operating trading subsidiaries here as CPD

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