Gifts mainly to organisations campaigning for the UK to leave the EU were not part of the appellant’s normal expenditure for the purposes of the normal expenditure out of income IHT exemption and were not eligible for the exemption for gifts to political parties.

Summary

Gifts mainly to organisations campaigning for the UK to leave the EU were not part of the appellant’s normal expenditure for the purposes of the normal expenditure out of income inheritance tax (IHT) exemption (within IHTA 1984, s 21) and were not eligible for the exemption for gifts to political parties (within IHTA 1984, s 24).

Background

From the tax years 2015/16 to 2022/23, the appellant made approximately £10.8m of charitable donations, and £11.9m of political donations (plus £25,000 in March 2011). The appellant’s charitable and political donations fluctuated significantly year to year,