Tax policy toward non-profit organisations: an eleven-country survey

The role of private non-profit organisations in modern economic systems is poorly understood. The tax and subsidy treatment of non-profits relative to private firms affects the competitive position of each, and thus their relative strength within any industry; in the United States, for example, non-profit organisations play major competitive roles in such industries as hospitals, nursing homes, day care centres, schools and arts organisations. This paper reports results from a survey of tax policies toward non-profit organisations in eleven countries. The major findings are: (1) the definition and scope of such organisations varies considerably; (2) non-profit organisations are typically regulated by the tax collection agency, but in some countries there is also involvement from the government agency responsible for the particular realm of activity, such as health or education; (3) tax subsidies to non-profits take many forms - not only exemption from corporate profits tax but, depending on the country, for land, buildings, mail and motor vehicles; (4) almost every country limits non-profit organisations' 'unrelated' business activities; and (5) donors are generally permitted to deduct donations of money from taxable income, although there are typically both minimum and maximum limits. These findings point up the larger task of understanding why such differences exist across countries, and what are the effects.