{"context":{"authority":"source-reported-claim","effect":"advisory","effectiveDate":null,"evaluatedOn":"2026-07-13","externalStateChange":false,"jurisdiction":"United Kingdom","knowledgeAsOf":"2026-07-13","subject":{"id":"uk-charities-sector.taxTreatments.tax-income-and-gains","type":"dataset-record","version":"2026-07-13.2"}},"coverage":{"boundaries":["Array positions are never record identity; each graph reference uses the stable treatment, source or gap ID.","Guidance and official summaries remain claims and sources; they are not labelled binding legal authority.","No charity, trustee, donor, beneficiary, belief, contact, transaction, tax amount or case file is present.","Record hrefs resolve the live dataset, not an immutable historical snapshot. Retain referenced records or compare context.subject.version before reusing a stored graph; no tombstone feed exists yet.","The SDLT treatment's context label is an admitted display union of its canonical England and Northern Ireland jurisdiction array; other future multi-territory labels fail closed.","The graph is derived from the immutable reviewed corpus snapshot and does not alter its hash or canonical records.","The public correction route corrects TaxSorted analysis and is not an official tax review or appeal."],"completeWithinDeclaredScope":false,"gapNodeIds":["gap:binding-provision-not-mapped","gap:case-applicability-not-assessed","gap:case-enforcement-and-challenge-not-mapped","gap:dataset:gap-charity-tax-case-law-effects-not-admitted","gap:dataset:gap-charity-tax-enquiry-closure-directions-not-mapped","gap:dataset:gap-charity-tax-wider-recovery-not-mapped"],"scope":"The reviewed statement, field-level evidence trace, possible benefit, reverse tax path and declared gaps for one UK charity-sector tax-treatment record; not case advice or a complete map of binding law, administration, collection, review or appeal."},"edges":[{"explanation":"The treatment evidence entry names this source for /benefit.","from":"claim:benefit","id":"edge:claim:benefit:supported-by:source:src-hmrc-tax-exemptions","relation":"supported-by","to":"source:src-hmrc-tax-exemptions"},{"explanation":"The treatment evidence entry names this source for /conditions.","from":"claim:conditions","id":"edge:claim:conditions:supported-by:source:src-hmrc-tax-exemptions","relation":"supported-by","to":"source:src-hmrc-tax-exemptions"},{"explanation":"The treatment evidence entry names this source for /eligibility.","from":"claim:eligibility","id":"edge:claim:eligibility:supported-by:source:src-hmrc-tax-exemptions","relation":"supported-by","to":"source:src-hmrc-tax-exemptions"},{"explanation":"The treatment evidence entry names this source for /notEquivalentTo.","from":"claim:not-equivalent-to","id":"edge:claim:not-equivalent-to:supported-by:source:src-hmrc-tax-exemptions","relation":"supported-by","to":"source:src-hmrc-tax-exemptions"},{"explanation":"The treatment evidence entry names this source for /position.","from":"claim:position","id":"edge:claim:position:supported-by:source:src-hmrc-tax-exemptions","relation":"supported-by","to":"source:src-hmrc-tax-exemptions"},{"explanation":"The treatment evidence entry names this source for /reasoningStatus.","from":"claim:reasoning-status","id":"edge:claim:reasoning-status:supported-by:source:src-hmrc-tax-exemptions","relation":"supported-by","to":"source:src-hmrc-tax-exemptions"},{"explanation":"The treatment evidence entry names this source for /reasoning.","from":"claim:reasoning","id":"edge:claim:reasoning:supported-by:source:src-hmrc-tax-exemptions","relation":"supported-by","to":"source:src-hmrc-tax-exemptions"},{"explanation":"The treatment evidence entry names this source for /whenTaxOrClawbackCanArise.","from":"claim:tax-or-clawback","id":"edge:claim:tax-or-clawback:supported-by:source:src-hmrc-tax-exemptions","relation":"supported-by","to":"source:src-hmrc-tax-exemptions"},{"explanation":"The treatment evidence entry names this source for /taxType.","from":"claim:tax-type","id":"edge:claim:tax-type:supported-by:source:src-hmrc-tax-exemptions","relation":"supported-by","to":"source:src-hmrc-tax-exemptions"},{"explanation":"The reverse path stays visible beside the possible relief.","from":"conclusion:tax-treatment:tax-income-and-gains","id":"edge:conclusion:tax-treatment:tax-income-and-gains:leads-to:consequence:tax-recovery-or-clawback","relation":"leads-to","to":"consequence:tax-recovery-or-clawback"},{"explanation":"The treatment keeps its stated effect separate from eligibility and failure paths.","from":"conclusion:tax-treatment:tax-income-and-gains","id":"edge:conclusion:tax-treatment:tax-income-and-gains:leads-to:consequence:treatment-effect","relation":"leads-to","to":"consequence:treatment-effect"},{"explanation":"This named boundary prevents the sector explanation from claiming case-level or legal completeness.","from":"conclusion:tax-treatment:tax-income-and-gains","id":"edge:conclusion:tax-treatment:tax-income-and-gains:limited-by:gap:binding-provision-not-mapped","relation":"limited-by","to":"gap:binding-provision-not-mapped"},{"explanation":"This named boundary prevents the sector explanation from claiming case-level or legal completeness.","from":"conclusion:tax-treatment:tax-income-and-gains","id":"edge:conclusion:tax-treatment:tax-income-and-gains:limited-by:gap:case-applicability-not-assessed","relation":"limited-by","to":"gap:case-applicability-not-assessed"},{"explanation":"This named boundary prevents the sector explanation from claiming case-level or legal completeness.","from":"conclusion:tax-treatment:tax-income-and-gains","id":"edge:conclusion:tax-treatment:tax-income-and-gains:limited-by:gap:case-enforcement-and-challenge-not-mapped","relation":"limited-by","to":"gap:case-enforcement-and-challenge-not-mapped"},{"explanation":"The native corpus declares this gap as affecting the treatment record.","from":"conclusion:tax-treatment:tax-income-and-gains","id":"edge:conclusion:tax-treatment:tax-income-and-gains:limited-by:gap:dataset:gap-charity-tax-case-law-effects-not-admitted","relation":"limited-by","to":"gap:dataset:gap-charity-tax-case-law-effects-not-admitted"},{"explanation":"The native corpus declares this gap as affecting the treatment record.","from":"conclusion:tax-treatment:tax-income-and-gains","id":"edge:conclusion:tax-treatment:tax-income-and-gains:limited-by:gap:dataset:gap-charity-tax-enquiry-closure-directions-not-mapped","relation":"limited-by","to":"gap:dataset:gap-charity-tax-enquiry-closure-directions-not-mapped"},{"explanation":"The native corpus declares this gap as affecting the treatment record.","from":"conclusion:tax-treatment:tax-income-and-gains","id":"edge:conclusion:tax-treatment:tax-income-and-gains:limited-by:gap:dataset:gap-charity-tax-wider-recovery-not-mapped","relation":"limited-by","to":"gap:dataset:gap-charity-tax-wider-recovery-not-mapped"},{"explanation":"This field group is part of the published explanation trace.","from":"conclusion:tax-treatment:tax-income-and-gains","id":"edge:conclusion:tax-treatment:tax-income-and-gains:reasoned-by:reasoning:classification","relation":"reasoned-by","to":"reasoning:classification"},{"explanation":"This field group is part of the published explanation trace.","from":"conclusion:tax-treatment:tax-income-and-gains","id":"edge:conclusion:tax-treatment:tax-income-and-gains:reasoned-by:reasoning:conditions","relation":"reasoned-by","to":"reasoning:conditions"},{"explanation":"This field group is part of the published explanation trace.","from":"conclusion:tax-treatment:tax-income-and-gains","id":"edge:conclusion:tax-treatment:tax-income-and-gains:reasoned-by:reasoning:effects","relation":"reasoned-by","to":"reasoning:effects"},{"explanation":"This field group is part of the published explanation trace.","from":"conclusion:tax-treatment:tax-income-and-gains","id":"edge:conclusion:tax-treatment:tax-income-and-gains:reasoned-by:reasoning:source-reading","relation":"reasoned-by","to":"reasoning:source-reading"},{"explanation":"This route can correct TaxSorted's derived explanation, not challenge an HMRC or court decision.","from":"conclusion:tax-treatment:tax-income-and-gains","id":"edge:conclusion:tax-treatment:tax-income-and-gains:reviewable-through:route:taxsorted-public-correction","relation":"reviewable-through","to":"route:taxsorted-public-correction"},{"explanation":"The canonical tax-or-clawback field grounds this conditional consequence.","from":"consequence:tax-recovery-or-clawback","id":"edge:consequence:tax-recovery-or-clawback:grounded-in:claim:tax-or-clawback","relation":"grounded-in","to":"claim:tax-or-clawback"},{"explanation":"The canonical benefit field grounds this conditional consequence.","from":"consequence:treatment-effect","id":"edge:consequence:treatment-effect:grounded-in:claim:benefit","relation":"grounded-in","to":"claim:benefit"},{"explanation":"The reasoning step reads these named fields on the canonical treatment record.","from":"reasoning:classification","id":"edge:reasoning:classification:uses-claim:claim:position","relation":"uses-claim","to":"claim:position"},{"explanation":"The reasoning step reads these named fields on the canonical treatment record.","from":"reasoning:classification","id":"edge:reasoning:classification:uses-claim:claim:tax-type","relation":"uses-claim","to":"claim:tax-type"},{"explanation":"The reasoning step reads these named fields on the canonical treatment record.","from":"reasoning:conditions","id":"edge:reasoning:conditions:uses-claim:claim:conditions","relation":"uses-claim","to":"claim:conditions"},{"explanation":"The reasoning step reads these named fields on the canonical treatment record.","from":"reasoning:conditions","id":"edge:reasoning:conditions:uses-claim:claim:eligibility","relation":"uses-claim","to":"claim:eligibility"},{"explanation":"The reasoning step reads these named fields on the canonical treatment record.","from":"reasoning:effects","id":"edge:reasoning:effects:uses-claim:claim:benefit","relation":"uses-claim","to":"claim:benefit"},{"explanation":"The reasoning step reads these named fields on the canonical treatment record.","from":"reasoning:effects","id":"edge:reasoning:effects:uses-claim:claim:tax-or-clawback","relation":"uses-claim","to":"claim:tax-or-clawback"},{"explanation":"The reasoning step reads these named fields on the canonical treatment record.","from":"reasoning:source-reading","id":"edge:reasoning:source-reading:uses-claim:claim:not-equivalent-to","relation":"uses-claim","to":"claim:not-equivalent-to"},{"explanation":"The reasoning step reads these named fields on the canonical treatment record.","from":"reasoning:source-reading","id":"edge:reasoning:source-reading:uses-claim:claim:reasoning","relation":"uses-claim","to":"claim:reasoning"},{"explanation":"The reasoning step reads these named fields on the canonical treatment record.","from":"reasoning:source-reading","id":"edge:reasoning:source-reading:uses-claim:claim:reasoning-status","relation":"uses-claim","to":"claim:reasoning-status"}],"nodes":[{"description":"Read benefit on the canonical treatment record. The graph does not turn the described benefit into an entitlement.","id":"claim:benefit","kind":"claim","label":"Potential tax benefit","record":{"collection":"taxTreatments","dataset":"uk-charities-sector","href":"/v1/charities/uk/tax-treatments/tax-income-and-gains","kind":"dataset-record","recordId":"tax-income-and-gains"},"state":"supporting"},{"description":"Read conditions on the canonical treatment record. Array positions are not identifiers and are not copied into this graph.","id":"claim:conditions","kind":"claim","label":"Conditions that keep the treatment conditional","record":{"collection":"taxTreatments","dataset":"uk-charities-sector","href":"/v1/charities/uk/tax-treatments/tax-income-and-gains","kind":"dataset-record","recordId":"tax-income-and-gains"},"state":"supporting"},{"description":"Read eligibility on the canonical treatment record. It is a general boundary, not proof that an organisation qualifies.","id":"claim:eligibility","kind":"claim","label":"Eligibility boundary","record":{"collection":"taxTreatments","dataset":"uk-charities-sector","href":"/v1/charities/uk/tax-treatments/tax-income-and-gains","kind":"dataset-record","recordId":"tax-income-and-gains"},"state":"supporting"},{"description":"Read notEquivalentTo on the canonical treatment record before carrying the statement into another system.","id":"claim:not-equivalent-to","kind":"claim","label":"What the treatment does not establish","record":{"collection":"taxTreatments","dataset":"uk-charities-sector","href":"/v1/charities/uk/tax-treatments/tax-income-and-gains","kind":"dataset-record","recordId":"tax-income-and-gains"},"state":"supporting"},{"description":"Read position on the canonical treatment record. It keeps conditional relief, taxable boundaries and TaxSorted analysis distinct.","id":"claim:position","kind":"claim","label":"Treatment position","record":{"collection":"taxTreatments","dataset":"uk-charities-sector","href":"/v1/charities/uk/tax-treatments/tax-income-and-gains","kind":"dataset-record","recordId":"tax-income-and-gains"},"state":"supporting"},{"description":"Read reasoning on the canonical treatment record while preserving the separate reasoningStatus voice label.","id":"claim:reasoning","kind":"claim","label":"Declared reasoning","record":{"collection":"taxTreatments","dataset":"uk-charities-sector","href":"/v1/charities/uk/tax-treatments/tax-income-and-gains","kind":"dataset-record","recordId":"tax-income-and-gains"},"state":"supporting"},{"description":"Read reasoningStatus on the canonical treatment record so an official summary never becomes TaxSorted analysis, or vice versa.","id":"claim:reasoning-status","kind":"claim","label":"Declared reasoning voice","record":{"collection":"taxTreatments","dataset":"uk-charities-sector","href":"/v1/charities/uk/tax-treatments/tax-income-and-gains","kind":"dataset-record","recordId":"tax-income-and-gains"},"state":"supporting"},{"description":"Read whenTaxOrClawbackCanArise on the canonical record. No case amount, notice or enforcement event is asserted.","id":"claim:tax-or-clawback","kind":"claim","label":"When tax, recovery or clawback can arise","record":{"collection":"taxTreatments","dataset":"uk-charities-sector","href":"/v1/charities/uk/tax-treatments/tax-income-and-gains","kind":"dataset-record","recordId":"tax-income-and-gains"},"state":"supporting"},{"description":"Read taxType on the canonical treatment record. It classifies the sector statement; it does not determine a case.","id":"claim:tax-type","kind":"claim","label":"Tax type","record":{"collection":"taxTreatments","dataset":"uk-charities-sector","href":"/v1/charities/uk/tax-treatments/tax-income-and-gains","kind":"dataset-record","recordId":"tax-income-and-gains"},"state":"supporting"},{"description":"A trace of one reviewed sector tax-treatment record. It explains the record and its evidence; it does not decide eligibility or tax for an organisation.","id":"conclusion:tax-treatment:tax-income-and-gains","kind":"conclusion","label":"Income and gains relief is conditional on charitable application","record":{"collection":"taxTreatments","dataset":"uk-charities-sector","href":"/v1/charities/uk/tax-treatments/tax-income-and-gains","kind":"dataset-record","recordId":"tax-income-and-gains"},"state":"supporting"},{"description":"The canonical reverse-path field names general circumstances only; no case liability, amount, notice or enforcement event is asserted.","id":"consequence:tax-recovery-or-clawback","kind":"consequence","label":"Tax, recovery or clawback may arise","record":{"collection":"taxTreatments","dataset":"uk-charities-sector","href":"/v1/charities/uk/tax-treatments/tax-income-and-gains","kind":"dataset-record","recordId":"tax-income-and-gains"},"state":"conditional"},{"description":"The canonical benefit field may describe relief or state that no additional benefit exists. It is not a computed entitlement or amount.","id":"consequence:treatment-effect","kind":"consequence","label":"Treatment effect described by the benefit field","record":{"collection":"taxTreatments","dataset":"uk-charities-sector","href":"/v1/charities/uk/tax-treatments/tax-income-and-gains","kind":"dataset-record","recordId":"tax-income-and-gains"},"state":"conditional"},{"description":"This compact graph selected no treatment-core provision for this treatment. The tax-rules collection may still publish exact supplementary or related provisions; query it by primary or related tax-treatment ID. No guidance source is promoted to binding law.","id":"gap:binding-provision-not-mapped","kind":"gap","label":"No core binding provision selected into this graph","record":null,"state":"not-mapped"},{"description":"No organisation, transaction, accounting period, tax facts, HMRC recognition state or amount is supplied or inferred by this sector-record graph.","id":"gap:case-applicability-not-assessed","kind":"gap","label":"Case applicability not assessed","record":null,"state":"not-applicable"},{"description":"The official-procedures collection maps conditional doors for return, assessment, payment, challenge and territorial recovery. This graph selects none without the exact notice, decision, date, tax branch and jurisdiction facts.","id":"gap:case-enforcement-and-challenge-not-mapped","kind":"gap","label":"No procedure route has been selected for a case","record":null,"state":"not-mapped"},{"description":"This canonical transparency-gap record names a limit that directly affects the treatment. Follow the record for its detail, consequence, status and evidence.","id":"gap:dataset:gap-charity-tax-case-law-effects-not-admitted","kind":"gap","label":"No reported-case holding is applied without a safely matched official decision","record":{"collection":"transparencyGaps","dataset":"uk-charities-sector","href":"/v1/charities/uk/gaps/gap-charity-tax-case-law-effects-not-admitted","kind":"dataset-record","recordId":"gap-charity-tax-case-law-effects-not-admitted"},"state":"not-mapped"},{"description":"This canonical transparency-gap record names a limit that directly affects the treatment. Follow the record for its detail, consequence, status and evidence.","id":"gap:dataset:gap-charity-tax-enquiry-closure-directions-not-mapped","kind":"gap","label":"Enquiry-opening records do not yet include taxpayer-initiated tribunal closure directions","record":{"collection":"transparencyGaps","dataset":"uk-charities-sector","href":"/v1/charities/uk/gaps/gap-charity-tax-enquiry-closure-directions-not-mapped","kind":"dataset-record","recordId":"gap-charity-tax-enquiry-closure-directions-not-mapped"},"state":"not-mapped"},{"description":"This canonical transparency-gap record names a limit that directly affects the treatment. Follow the record for its detail, consequence, status and evidence.","id":"gap:dataset:gap-charity-tax-wider-recovery-not-mapped","kind":"gap","label":"Three territorial recovery branches are admitted, not the full recovery system","record":{"collection":"transparencyGaps","dataset":"uk-charities-sector","href":"/v1/charities/uk/gaps/gap-charity-tax-wider-recovery-not-mapped","kind":"dataset-record","recordId":"gap-charity-tax-wider-recovery-not-mapped"},"state":"not-mapped"},{"description":"This step groups stable fields on the canonical treatment record; it does not copy an array position or create a new legal conclusion.","id":"reasoning:classification","kind":"reasoning-step","label":"Classify the treatment without applying it to a case","record":{"collection":"taxTreatments","dataset":"uk-charities-sector","href":"/v1/charities/uk/tax-treatments/tax-income-and-gains","kind":"dataset-record","recordId":"tax-income-and-gains"},"state":"supporting"},{"description":"This step groups stable fields on the canonical treatment record; it does not copy an array position or create a new legal conclusion.","id":"reasoning:conditions","kind":"reasoning-step","label":"Keep eligibility and conditions attached","record":{"collection":"taxTreatments","dataset":"uk-charities-sector","href":"/v1/charities/uk/tax-treatments/tax-income-and-gains","kind":"dataset-record","recordId":"tax-income-and-gains"},"state":"supporting"},{"description":"This step groups stable fields on the canonical treatment record; it does not copy an array position or create a new legal conclusion.","id":"reasoning:effects","kind":"reasoning-step","label":"Separate the possible benefit from the reverse tax path","record":{"collection":"taxTreatments","dataset":"uk-charities-sector","href":"/v1/charities/uk/tax-treatments/tax-income-and-gains","kind":"dataset-record","recordId":"tax-income-and-gains"},"state":"supporting"},{"description":"This step groups stable fields on the canonical treatment record; it does not copy an array position or create a new legal conclusion.","id":"reasoning:source-reading","kind":"reasoning-step","label":"Preserve source voice and stated limits","record":{"collection":"taxTreatments","dataset":"uk-charities-sector","href":"/v1/charities/uk/tax-treatments/tax-income-and-gains","kind":"dataset-record","recordId":"tax-income-and-gains"},"state":"supporting"},{"description":"The public GitHub tracker needs an account and is only for non-personal factual corrections. Never post tax facts, identity data, confidential client material or safeguarding information.","id":"route:taxsorted-public-correction","kind":"route","label":"Correct this TaxSorted explanation","record":{"href":"https://github.com/cambridgetcg/taxsorted.io/issues","kind":"external-resource"},"state":"available"},{"description":"Read the canonical source record for publisher, authority level, review dates, reuse status, supported statements and stated limits.","id":"source:src-hmrc-tax-exemptions","kind":"source","label":"Annex i: tax exemptions for charities","record":{"collection":"sources","dataset":"uk-charities-sector","href":"/v1/charities/uk/sources/src-hmrc-tax-exemptions","kind":"dataset-record","recordId":"src-hmrc-tax-exemptions"},"state":"supporting"}],"ordering":{"edges":"id-ascii-ascending","nodes":"id-ascii-ascending","setValues":"unique-ascii-ascending"},"rootNodeId":"conclusion:tax-treatment:tax-income-and-gains","schema":"taxsorted.why-graph/1","valueHandling":{"factValues":"case-financial-and-identity-fact-values-not-copied-into-graph","nodeIds":"semantic-identifiers-without-fact-values-or-array-positions"}}