A loan by a charity to a donor company of which a director was also a trustee of the charity was not an approved charitable investment for tax purposes.
Summary
A loan by a charity to a donor company of which a director was also a trustee of the charity was not an approved charitable investment for tax purposes (within ITA 2007, s 558, Type 12).
Background
The appellant (RMF) was registered as a charity. RMF had two trustees, one of whom (JP) was director of a company (G), a wholly-owned subsidiary of another company (BH), which was in the business of providing short term bridging finance for property development.
G made several donations to RMF during the periods under consideration.â¯By a contract dated 10 March 2006, RMF made a loan facility available
