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FA 2011¹ introduced new anti-avoidance legislation to counteract the abuse of tax relief available to donors who gift to charities (including registered community amateur sports clubs — CASCs², see Division B5.9) and it applies to relievable charity donations made on or after 1 April 2011.

The legislation has been introduced following representations that the substantial donors legislation (see B5.851) was too cumbersome and administratively time-consuming. It disapplies some of the substantial donors legislation before 1 April 2013, and broadly repeals it from that date. However, contractual obligations entered into before 1 April 2013 continue to be covered by the substantial donors legislation, but where the contract is varied on or after that date the existing rules will then no longer apply and the situation will be considered under these new tainted donations rules³.