File note of the mechanism under which Bodleian trading activities are correctly accounted for
Guidelines have been agreed between HM Revenue & Customs and sector representative bodies for the Corporation Tax treatment of UK Universities. These reflect UK legal obligations, with further clarification from the Charity Commission on the interpretation of public benefit.
These Guidelines endorse the standard sector model for non-primary purpose trades to be carried out as the activities of a subsidiary company. The subsidiary can use Corporate Gift Aid relief to mitigate its taxable profits by way of a donation to the university.
The University of Oxford operates a group of subsidiary companies to conduct potentially taxable trades which are nonetheless complementary to its primary purposes. The University also acts as undisclosed agent of a trading subsidiary to account for the broad miscellany of individual non-primary purpose activities associated with Departments of the University.
John Huke 20 April 2012