Contents
Foreword
 
Part I: Charities and the tax system

Chapter 1 - Purpose of the review

Chapter 2 - Government assistance to the charitable sector through the tax system
 
Part II: The relevance of the definition of "charitable purpose"

Chapter 3 - Current law

Chapter 4 - Why review the definition of "charitable purpose"

Chapter 5 - Options for changing the definition
 
Part III: Reporting requirements for charities

Chapter 6 - Current law and practice

Chapter 7 - Why increased reporting is necessary

Chapter 8 - Options for change
 
Part IV: Specific income tax issues

Chapter 9 - Charities' trading operations

Chapter 10 - Charities with purposes outside New Zealand

Chapter 11 - The tax treatment of donations made by individuals and companies

Chapter 12 - Other income tax issues
 
Part V: GST

Chapter 13 - GST issues

Appendix - International comparisons
Tax and charities

Discussion Document

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Chapter 4 - Why review the definition of "charitable purpose"?

Part II

4.1 Two main factors are behind the government's interest in reviewing the definition of "charitable purpose": that the charitable tax exemption may be too widely available, and it may be out of date. It may be that these problems are problems of perception only. The government has little information about the scope and cost of the tax exemption, so it is difficult to tell whether these problems are at the margin or are more general. For this reason, the reporting proposals discussed in chapter 8 are key.

4.2 Some sectors of the community have expressed concern that the charitable tax exemption is too widely available, and may be being used by some businesses to gain an advantage over their competitors. In that respect, it could be argued that the legal concept of a charity is now somewhat remote from the popular perception that a charity connotes "worthy" causes. These causes might involve the giving of assistance to less fortunate members of society, or providing for other activities that have clear and discernible benefits to the community as a whole. It is unlikely that in the public's mind, the New Zealand Council for Law Reporting and the Medical Council, for example, would be considered charitable in the same way as, say, the Salvation Army or the Red Cross.

4.3 Furthermore, a definition used to make decisions about what is, in effect, government expenditure, and that is based on law up to 400 years old, should be reviewed in the light of the needs of New Zealand in the 21st century. The government is concerned to ensure that tax assistance is directed to those charitable purposes and activities that have broad-based community acknowledgement and support, and that those in greatest need of those resources have access to them. The fiscal privileges accorded to charities make it imperative that the definition of "charitable purpose" accords with society's current objectives.

4.4 Other factors are that:

  • Concerns have been expressed that in some cases the benefit to society provided by an organisation is incidental to some other purpose it has undertaken.
  • As a technical matter, the definition of "charitable purpose" refers only to organisations established exclusively for charitable purposes. There is an argument that because of this, there is no legislative authority to challenge the tax exemption of an organisation that was established for, but no longer pursues, the relevant charitable purposes.



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