An entity for the purposes of income tax exemption as a tax exempt sporting club includes a corporation, unincorporated association, a trust or a partnership.

Income tax exemption will not apply to a group of entities collectively described as 'the club'. Each particular entity in the group must assess its own income tax exempt status.


A sporting group includes two incorporated associations. One association operates a leagues club and the other a football club. Each entity, the leagues club and the football club, must assess its own income tax exempt status. This would be the case irrespective of whether the sporting group was referred to collectively as 'the club'.

The following features on their own, will not be sufficient to show that your club is exempt:

  • control of your club by an exempt entity or entities
  • common membership of the board of both your club and the exempt entity
  • use of your club's surplus funds for exempt entities or their purposes
  • the commitments of members of your club being related to those of an exempt entity or entities
  • common motives inspiring your club and associated exempt entities
  • the providing of free services to associated exempt entities
  • the holding of property by your club on trust for exempt entities.

The consolidation regime - under which a consolidated group of entities is treated as a single entity for income tax purposes - does not apply to income tax exempt entities.

    Last modified: 21 Mar 2011QC 23868