Oxford University Press's failed claim in 1950 for exemption from Income Tax

Internal I.R. briefing to G. W. Booth and the Private Secretary, 18th July 1950

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CHIEF INSPECTOR OF TAXES (CLAIMS)

Reference: P.S.1199/50

Oxford University Press

1. Mr Booth.
2. Private Secretary.

I would assume that the University is entitled to exemption from Income Tax in respect of Oxford University Press premises and investment income. The premises will be occupied by the University, and despite use for a purpose which is partly commercial rather than charitable, will fall within Finance Act, 1921, Section 30(1)(a). If investment income is free to be applied to the University's general charitable purposes, exemption could be allowed under Income Tax Act, 1918, Section 37(1)(b) for even if such income is applied to purposes connected with the Press it will be possible to say that it is applied towards the educational and, therefore, charitable work of the Press. If, however, the investment income is not free, we would require information about the rules or statutes governing its application.

There is, of course, no claim at present, and we do not know what properties or income could be relieved from tax. There is insufficient information in the main folder of the Oxford University Chest to construct details of the claim. May I suggest that the possibility of a claim should be mentioned to the University Authorities with a general indication of what might be included? The Authorities can then ascertain what properties and income are not relieved from tax and can make a claim to this Branch.

[handwritten notes:] The Chairman might tell the University people that on examining the papers we have come to the conclusion that they could claim (a) exemption from Schedule A tax on premises owned and occupied by the Oxford University Press and (b) relief from Income Tax on investment income of the Press if that income is free to be applied to the general charitable purposes of the University. Claims to these reliefs will be admissible subject to the usual six year time limit laid down by statute.

(For Profits Tax we should bring in income from investments of the printing, publishing, paper mill, etc businesses of the Press in computing the Profits Tax liability on the profits of the Press, notwithstanding that exemption from Income Tax might be due on a part - or the whole - of the income.)

I think that the simplest course would be for the Chairman to ask the Press to put their accountants in touch with the Claims Branch to examine the question.

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