Commentary on Sections Overview Section 551: Non-charitable expenditure in substantial donor transactions
1657.This section specifies that certain amounts relating to substantial donor transactions are to be treated as non-charitable expenditure. It is based on sections 506A(3) to (5) and 506C(2) and (6) of ICTA.
1658.The source legislation specifies that certain matters are to be determined by the Commissioners for Her Majesty’s Revenue and Customs. References to “the Commissioners for Her Majesty’s Revenue and Customs” have been replaced with references to “an officer of Revenue and Customs”. See Change 5 in Annex 1, which also affects sections 554 and 557. The source legislation specifies that, on an appeal against an assessment, the Special Commissioners may review a decision of the Commissioners, so section 557 specifies that the Special Commissioners may affirm or replace a decision of an officer.