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Cancer Research UK
Angel Building
407 St John Street
London ECIV 4AD
United Kingdom
T 020 7242 0200
www.cancerresearchuk.org
29 April 2017
Dear Sir / Madam,
RE: Cancer Research UK’s response to the Green Paper On the future of VAT
Towards a simpler, more robust and efficient VAT system
Cancer Research UK is the world’s leading charity dedicated to beating cancer through
research. In 2009/10, our total research spend was around €396 millioni. We receive no
government funding for our research. We are the UK’s largest fundraising charity and the
largest independent funder of cancer research in Europe. We have around 45,000
volunteers who generously donate 7 million hours of their time each year. Our
groundbreaking work has saved millions of lives.
We welcome the opportunity to respond to this consultation and agree with the points
raised by the Charity Tax Group in its response. Specifically, we are concerned about the
following issues.
Firstly, the VAT system is often considered from the perspective of businesses and the
state, but less from the perspective of charities, which often have fewer resources to make
their case in consultation responses such as these. The charity sector’s situation should
be properly considered if and when reforms of the VAT system take place, especially
given the important contribution of charities and Non-Governmental Organisations (NGOs)
to citizens across Europe. This is particularly important as the role of the ‘state’ changes
and more services are outsourced to charities and social enterprise organisations.
Secondly, the current VAT system places significant financial and compliance burdens on
charitable organisations. We urge the Commission to ensure that any reform to the VAT
system should attempt to reduce these burdens and to ensure, at the very least, that
these burdens are not allowed to increase. At present Cancer Research UK is subject to
irrecoverable VAT to the order of €6.5m per annum. This money could cover the cost of
running six labs within the Cancer Research UK London Research Institute for around a
year. Scientists at the institute are conducting intricate lab studies to discover exactly how
and why cancer develops. This knowledge is essential for developing new ways of
preventing, diagnosing and treating cancer.
Finally, the charity sector in the UK benefits from a number of VAT reliefs. Removal of
such social exemptions would be very damaging to charities and reduce the amount of
money available to spend on their causes. We agree with the Charity Tax Group that the
Commission should undertake thorough impact assessments in order to ascertain the
Patron Her Majesty The Queen
Presidents HRH The Duke of Gloucester KG GCVO and HRH Princess Alexandra, the Hon. Lady Ogilvy KG GCVO
Chief Executive Harpal S. Kumar
Cancer Research UK is a registered charity in England and Wales (1089464) and in Scotland (SC041666). Registered as a company limited by guarantee in England and Wales no. 4325234.
Registered address: Angel Building, 407 St John Street, London EC1V 4AD
importance of such reliefs for the charity sector. It is essential that the severe social and
economic implications for charities and their beneficiaries of removing exemptions are
given serious consideration.
Radical reform should only be considered where that reform is appropriate and its impact
is proportionate. In particular, regulation of VAT should not be allowed to create artificial
barriers that prevent tax neutrality and, as a result, distort the effective roles of state and
charity.
Yours faithfully,
Layla Theiner
EU Public Affairs Manager
i
Converted from GBP to EUR on 26 November 2010 (www.xe.com/ucc/)
Patron Her Majesty The Queen
Presidents HRH The Duke of Gloucester KG GCVO and HRH Princess Alexandra, the Hon. Lady Ogilvy KG GCVO
Chief Executive Harpal S. Kumar
Cancer Research UK is a registered charity in England and Wales (1089464) and in Scotland (SC041666). Registered as a company limited by guarantee in England and Wales no. 4325234.
Registered address: Angel Building, 407 St John Street, London EC1V 4AD