Primary purpose attracts no tax

As Legal Charity Commissioner from 1989 to 1997, I read the article in The Lawyer (14 June) "Charities require masters of all trades", with interest. However, there is one passage (highlighted in the middle of the text) which is not completely accurate and is therefore misleading. It is not true to say that "If more than 10 per cent of a charity's revenue is raised through trade, the Inland Revenue can tax all of its revenue."

There is a very important exception to this proposition: where the trading activity represents the means by which the charity achieves its purpose rather than merely raising funds for use in achieving its purpose. This is known in the "trade" as "primary purpose trading", and is exempt from income tax.

As there are a good number of charities which do this, it is important that the matter be corrected.

Robert Venables, consultant,

Bircham & Co, London SW1