Section A: Background

3.2 Gift Aid pre-April 2000

3.2.1 The original Gift Aid Scheme was introduced in 1990. It enabled United Kingdom resident individuals and companies to give single gifts of money to charity tax-effectively, but it required a minimum amount to be given. Non-close companies could give any amount.

3.2.2 The individual or company made a donation net of basic rate tax and gave the charity a certificate (R190(SD) for individuals and R240(SD) for companies). The individual must have had at least as much income chargeable at the basic rate as the amount of the gross donation. Companies were required to deduct basic rate tax from the donation and pay it over to HM Revenue & Customs.

3.2.3 If the individual paid tax at the higher rate he or she could get relief on the gift on the difference between the basic and higher rate on the grossed-up amount. A company deducted the grossed up amount of the donation as a charge in its corporation tax computation.

3.2.4 Charities receiving Gift Aid donations could reclaim basic rate tax on the donations, provided they were in receipt of a valid certificate from the donor and could demonstrate a clear audit trail linking the donation to the donor.

3.2.5 If the donor received benefits from the charity worth more than 2.5% of the net gift, the gift would not qualify for Gift Aid. The maximum total benefits received by the donor from any one charity in a tax year could not be worth more than £250.

3.3 Tax relief for covenanted donations to charity pre-April 2000

3.3.1 Regular payments made by individuals and companies to a charity under a Deed of Covenant were paid after deduction of basic rate tax. The charity could claim back from HM Revenue & Customs the basic rate tax deducted from the payment.

3.3.2 The individual must have paid at least as much income tax at the basic rate as the amount of tax reclaimed by the charity on the payment. If the amount reclaimed by the charity exceeded the amount paid by the covenantor, HM Revenue & Customs might require the individual to pay the tax difference. Companies were required to deduct basic rate tax from the covenanted payment and pay it over separately to HM Revenue & Customs.

3.3.3 If the individual paid tax at the higher rate, he or she could get relief on the payment on the difference between the basic and higher rate on the grossed-up amount.
A company deducted the gross amount of the payment as a charge in its corporation tax computation.

3.3.4 Charities receiving covenanted payments could reclaim basic rate tax on the payments made, provided the covenant was legally valid, lasted for over three years and a clear audit trail could be demonstrated linking the payment to the donor.

3.3.5 There was no statutory limit on the benefits which could be received in relation to payments made to a charity under a Deed of Covenant. However, for payments of £100 made under a Deed to a membership charity, benefits up to 25% of the net amount of the payments were ignored for tax purposes.