We have prepared a guidance note for member trusts of Supporters Direct Scotland which are incorporated as Community Benefit Societies, as there is a common misconception that CBSs are not liable to pay corporation tax. This note seeks to explain the true position.
It is acknowledged that some member organisations will operate purely as supporter trusts while others are supporter owned football clubs. The latter will have more varied activities and so their tax issues will be more complex. However many trusts with no investment in their club also undertake commercial activities and so they too will have an exposure to corporation tax.
For supporter trusts acting as a parent company to a football club incorporated as a company limited by shares, the guidance will be relevant only to the parent trust and the tax affairs of the subsidiary football club will be outside the scope of this note. Trusts with such a structure should undertake planning to minimise their overall tax liability, taking professional advice where necessary.
The note is general in nature and does not aspire to address the individual circumstances of all trusts and so members should exercise appropriate caution when acting on the guidance set out within it, and should obtain professional advice if further clarification of corporation tax rules applicable to their circumstances is needed.