Commentary on Sections Overview Section 549: Transactions with substantial donors
1651.This section defines “substantial donor transaction” and explains when a person is a substantial donor to a charitable trust. It is based on sections 506A(1) and (2) and 506C(3) of ICTA.
1652.Under subsection (2)(a) a person giving £25,000 or more in a period of 12 months will be a substantial donor for up to three consecutive tax years.
1653.Under subsection (2)(b) a person giving £100,000 or more in a period of six years will be a substantial donor for up to 13 consecutive tax years.
1654.In either case,subsection (3) means that the person is also a substantial donor for the five tax years following the last of those consecutive tax years.
1655.It should be noted that references to a charitable trust include connected charities (see section 556) and that references to a substantial donor include persons connected with the donor (see section 557(1)(a)).