VTUPB5600 - Trade unions and professional bodies: Item 1(c) branch of knowledge / professional expertise: Professions or employments directly connected

鈥淣ote 4鈥 excludes associations from exemption under 鈥淚tem 1(c)鈥 unless the membership is restricted 鈥渨holly or mainly to individuals whose present or previous professions or employments are directly connected with the purposes of the association鈥.

There are two separate requirements within this note -

  • being restricted to 鈥渋ndividuals鈥, and
  • having the 鈥渆mployment鈥 connection.

However, following the ECJ decision in the Institute of the Motor Industry (referred to in VTUPB1200) HMRC takes the view that membership need not be restricted to individuals.

You should apply the same 75% criterion that we apply in 鈥淚tem 1(b)鈥 cases - see VTUPB4300.