BIM24010 | Meaning of trade: mutual trading and members clubs: income derived solely from members’ contributions and subscriptions
From HM Revenue & Customs · Business Income Manual
Not mutual trading
Where entities in the categories listed below derive their income solely from members' subscriptions and contributions, they do not normally carry on a trade. An entity that does not carry on a trade cannot be a mutual trader.
Trade/professional associations
Ordinary trade or professional associations, being non-trading bodies formed to protect the common interests of members, and deriving their funds from annual subscriptions etc paid by members. For detailed guidance on trade protection associations see .
Members' clubs
Members’ clubs established for social or recreational purposes (in this connection, see onwards, and for trading by clubs with non-members).
Companies limited by guarantee and with non-trading objects
Other bodies incorporated (for example, by Royal Charter or as companies limited by guarantee, usually with authority to omit ’limited' from the registered name) for non-trading objects, and deriving their funds wholly or mainly from members' subscriptions or from donations towards such objects. For guidance on Chambers of Commerce see .
Unincorporated associations
Unincorporated societies, associations etc (for example, societies registered under the Friendly Societies Acts and trade unions). Where, exceptionally, the association, etc. provides goods or services to members on a commercial basis for payment then you should (where the sums merit enquiry) look to see if this amounts to a trade. And where the association, etc. does conduct such a trade you will need to establish if the activities amount to a mutual trade, the profits from which are not taxable as trading income.
For discussion of whether income is trading income see , and for further guidance on mutual trading see onwards.