2013 Consultations

Consultation: Community Amateur Sports Clubs:

Consultation Launched: 3rd June 2013
Consultation Closes: 12th August 2013

  1. This 44-page consultation from HMRC lays out proposals to amend the qualifying conditions and allow clearer, more detailed, rules to be specified in secondary legislation following a public consultation. 
  2. The full consultation document can be found at:
  3. Chapter 4 sets out what is meant by the qualifying condition that a club must be ‘open to the whole community’. It focuses on the cost of membership and participation. The consultation seeks views on the maximum amount that a club can charge for membership and participation and qualify as a CASC. It proposes a maximum amount of up to £1,040 a year (£20 a week). This amount would include all the costs to a member for them to be able to participate in the sport.
  4. Chapter 4 also suggests how clubs that have to charge fees above the maximum amount might still be eligible for CASC status. Clubs would have to make appropriate arrangements to ensure those on low and modest incomes can fully participate. For example, a club could charge reduced rates for members on a low or modest income.
  5. Chapter 5 sets out the changes proposed to the qualifying condition that a club must be ‘organised on an amateur basis’. The consultation document proposes that a club can pay one player to play and that they can pay such a player a maximum of £5,000 a year.
  6. Chapter 5 also explores options for improving the current rules on expenses. Proposals include allowing clubs to pay players overnight subsistence costs such as hotels and evening meals in addition to travelling expenses. Chapter 5 also seeks views on the conditions that would need to be met if a club pays the expenses of playing members when they go on tour.
  7.  Chapter 6 proposes definitions of a social member and a guest for the purposes of the scheme. The chapter also seeks views on the percentage of social members a club should be able to have at any one time and still be considered a sports club.
  8. Chapter 7 seeks views on the detailed rules to apply to a new qualifying condition on income. The purpose of this condition is to specify how much social and other non-sporting income a club should be able to raise and still remain within the scheme. This chapter sets out four possible options.
  • Option 1 – Members income test. There would be no limit on any income from members. However there would be a limit on turnover from non-members of 20% as a percentage of total incomings of the club, capped at £25,000.
  • Option 2 – Basic income test. This is a simple test that would limit only non-sporting turnover of a club. The proposed limit for non-sporting income is 30% of the total turnover, capped at £100,000.
  • Option 3 – Different limits for different streams of income. This option would limit the turnover from various income streams such as the supply of food and drink (30%) and hiring of facilities (20%).
  • Option 4 – Days open test. This option would not limit the amount of income that is generated on the days sport was taking place. In addition the club could open on non-sporting days for a certain number of days through the year.
  1. The Government is seeking views on the details of these options and any views on alternative suggestions.
  2. Chapter 8 sets out the changes the Government is proposing to help certain clubs retain their CASC status where they have high levels of social income. One of those options would be to extend corporate Gift Aid, which currently applies only to donations to charities. Trading subsidiaries of CASCs would be able to pay little or no tax on their profits by donating their profits to their parent CASC.
  3. Chapter 8 also proposes to increase the Corporation Tax exemption limits for CASCs on trading income and rental income from £30,000 and £20,000 to £40,000 and £25,000 respectively.
  4. The Government also welcomes other suggestions for improving the qualifying conditions for CASCs.

Welsh Government Consultation - Business Rate Relief for Charities, Social Enterprises and Credit Unions – Recommendations from an independent report to the Welsh Government

Consultation launched: 23 April 2013
Consultation closes: 19 June 2013

In October 2012, the Welsh Government responded to the recommendations of the Business Rates Review Wales, an independent report from the Business Rates Task and Finish Group.   Recommendation 15 proposed consultation with the charitable and retail sectors to review the business rates reliefs that are available to charities and social enterprises.  The Minister for Economy, Science and Transport asked the Task and Finish Group to undertake this consultation and prepare specific recommendations on this issue.  The IRRV provided written and oral response to this process.

Their independent report has now been published and makes ten recommendations as well as further issues for consultation.

The Welsh Government seeks views on these recommendations. These responses will inform any further action that is taken. This consultation will run for eight weeks and builds on the engagement already undertaken by the Task and Finish and the previous call for evidence.

Summary of Recommendations:

Recommendation 1 - Use Planning Class

It is not recommended that a new Use Planning Class be introduced at this stage, but further consideration should be given to enabling the aims of such a change to be realised.

Recommendation 2 - Zoning

Any approach that is adopted to zone or limit the number of charity shops in a given area should be done at a devolved level of responsibility; this should be a matter for local authorities.

Recommendation 3 - Business Improvement Districts

Charity shops and their representative associations should be encouraged to fully participate as members of local organisations such as BID schemes that aim to rejuvenate and develop high streets in our towns and city centres.

Recommendation 4 - Bringing Long-Term Empty Property into Use

Any business which takes up new occupation of a property which has been vacant for 12 months or more would enjoy rate relief of 50% for the FIRST year of occupation.

Recommendation 5 - Bringing Long-Term Empty Property into Use

A business occupying a RETAIL property in a town centre that has been vacant for 12 months or more would enjoy 50% rate relief for TWO years. In addition, social enterprises may apply to have this 50% rate relief extended beyond two years at the discretion of the local authority.

Recommendation 6 - Tax Avoidance

The government should consider the following measure to tackle tax avoidance: all commercial premises that are occupied and used for charitable purposes could be subject to an upper RV limit of, say, £36K.

Recommendation 7 - Diversity on the High Street

New thresholds for charity shop rate relief should be created that will limit the amount of relief available for charity shops occupying premises of higher Rateable Value. These changes should be phased in for existing charity shops.

Recommendation 8 - Rateable Value Thresholds

The RV thresholds set out above should be reviewed at the time of the 2017 Rating List and subsequent Rating Lists. The threshold RVs may then rise or fall according to the tone of the List.

Recommendation 9 - Future Rating List

When the next Rating List for 2022 is introduced, consideration be given to reducing the mandatory 80% charitable relief to 50% for all charity shops and that as much as possible of charitable reliefs should be left to the discretion of the local authorities.

Recommendation 10 - Monitoring of New Goods Sales

To further address the issue of unfair competition on the high street, the amount of new goods being sold by charity shops be more effectivelymonitored by charitable organisations themselves (e.g. the CRA) - particularly in the run up to the Christmas period.

Download Wales NDR Charity Consultation

IRRV Comments:

Download the IRRV comments in PDF Format


Dynamic Benefits

The President of the Institute has received the following reply to our 105 questions from the Minister for Welfare Reform. We will be following this up immediately as well as sending further questions. As we get the answers we will post them on the website in a specific area that will be open to all.

Response from Lord Freud

Letter to Lord Freud

The position of the Institute has been to support the principles behind Dynamic Benefits and further to support the introduction of the Universal Credit; however the IRRV cannot support the inclusion of housing costs in Lord Freud's proposals.

Below is a draft of the letter sent to Lord Freud by the Institutes President Kerry Macdermott

My Institute is the only professional body in the United Kingdom that specialises in the law and practice of local authority revenues and local taxation collection together with the income related benefits that support these processes.

The position of the Institute has been to support the principles behind Dynamic Benefits and further to support the introduction of the Universal Credit; however we cannot support the inclusion of housing costs in your proposals.

There are many reasons behind this statement and in order to give your officials every opportunity to advise you to step back from a potential disaster that will make the Community Charge pale into insignificance we wish to offer you a constructive dialogue which will assist your thinking. The dialogue will be in the form of a series of questions which we hope, as you answer them; will give you an insight into the problems you will be facing.

The questions will be posted on the open area of our website and we will post the answers as your officials provide them. We hope you will welcome this approach and allow every opportunity for a constructive dialogue to take place which will assist you in the difficult decisions you will have to make over the next two years.
The first one hundred or so questions are attached and these have all been raised by practitioners as important issues that will need to be addressed to ensure a successful implementation of the Universal Credit.

May I also take this opportunity to personally thank you for the support you have given the Institute at our recent conferences. If your officials need any clarification on the questions, can they contact the Institutes Chief Executive David Magor ondavid.magor@irrv.org.uk

Link to 105 First Questions

Download Questions 

Download Letter


Business Rates: New Build Empty Property (England only)

Consultation launched: 12th June 2013
Consultation closes: 26th July  2013

1.      This 11-page consultation from DCLG lays out proposals to exempt all newly built commercial property completed between 1 October 2013 and 30 September 2016 from empty property rates for the first 18 months, up to the state aids limits. This document sets out the government’s proposals for the delivery of that policy and seeks consultees’ views on them. The full consultation document can be found at:



Parliamentary Work and Pensions Committee: Inquiry into Jobcentre Plus (JCP).

Link: http://www.parliament.uk/business/

Opening date: 19 April 2013.

Closing date: Friday 24th May

The inquiry will focus on the services JCP offers to benefit claimants, jobseekers and employers and its relationships with external providers and stakeholders such as local authorities, in the context of recent and ongoing welfare reforms,  including the introduction of  Universal Credit, and the resulting changes to JCP staff roles.

The Committee will consider the future of JCP as a public employment service, including its role as “gatekeeper” to contracted-out services such as the Work Programme and Work Choice. It will also assess the support which JCP currently provides to jobseekers in the early months of their unemployment benefit claim, before referral to external providers.

The inquiry will also assess whether the organisational changes in JCP since 2011 have produced efficiencies and streamlined management processes as intended.

Submissions of no more than 3,000 words are invited from interested organisations and individuals.  The Committee is particularly interested in the issues set out below. Submissions do not need to address all of these points.

  • JCP’s employment services, including: approaches to identifying jobseekers’ needs and barriers to employment; the effectiveness of the “Get Britain Working” measures; JCP’s role as a gateway to contracted-out services such as Work Choice and the Work Programme, including processes for referral and handover; JCP’s use of the Flexible Support Fund, including how spending decisions are made and evaluated; and the effectiveness of JCP’s relationships with other key stakeholders, particularly local authorities.
  • JCP’s role in relation to the rights and responsibilities of benefit claimants, including: the effectiveness of benefit conditionality, particularly job-seeking conditionality and the mandatory “work-focused interview”; and the level and appropriateness of JCP’s use of benefit sanctions, including differences of approach between JCP Districts. 
  • Supporting a flexible labour market, including: JCP’s effectiveness  in matching jobseekers to suitable job vacancies, including through the introduction of Universal Jobmatch; whether JCP is sufficiently focused on sustained job outcomes as well as off-benefit flows and how this is, or should be, measured; and employers’ assessment of the effectiveness of JCP as a recruitment partner.
  • The impacts of benefit reforms, including: the implications for JCP staff roles of the implementation of Universal Credit, including the skills staff will need in order to offer effective in-work support; changes to staff roles brought about by the move to “digital by default”; and plans to support claimants affected by the benefit cap
  • The governance of JCP, including: whether ending the executive agency status of JCP, and bringing it under the central control of a single DWP Chief Operating Officer, has brought about efficiencies and streamlined management as intended; and the potential for more radical future changes to JCP. 

IRRV Response:

Download the IRRV submission in PDF Format