Conservative and Unionist Central Office v Burrell

Conservative and Unionist Central Office v Burrell [1981] EWCA Civ 2[1] is an English trusts law case ruling on the "beneficiary principle".

The Inland Revenue sought to define the party, a mixed-money, common-object body with regular spending for political purposes, as an unincorporated association.

The direct subject matter was on the applicability of corporation tax, which was confirmed to apply to unincorporated associations but that the set-up of the party and its rules were not such an instance.

Vinelott J at first instance in the Chancery Division of the High Court (Conservative and Unionist Central Office v Burrell [1980] 3 All ER 42) held that each contributor enters a contract with the treasurer, who undertakes to use the subscription for the association's purposes.

The Court of Appeal held there was no contract which connected the branches of the party with the members tightly among themselves (inter se), so the Re Recher analysis could not apply.