An examination of tax-deductible donations made by individual Australian taxpayers in 2017-18

extent and characterisitcs of tax-deductible donations made and claimed by Australian taxpayers to Deductible Gift Recipients (DGRs) at Item D9 Gifts or Donations in their individual income tax returns for the 2018–19 income year. While section 1.3 of this Executive Summary provides a more detailed overview, analysis of the ATO data showed that the total amount donated and claimed as tax deductible donations in 2018–19 was $3.93 billion (compared to $3.75 billion for the previous income year). This constitutes an increase of 4.85 per cent or $182 million from the previous income year. The average tax-deductible donation made to DGRs and claimed by Australian taxpayers in 2018–19 was $933.20 (compared to $845.73 in the previous income year).


WHAT IS A TAX-DEDUCTIBLE GIFT?
According to Division 30 of the Income Tax Assessment Act 1997 (Cth) (ITAA 1997), taxpayers are entitled to claim a tax deduction for gifts (i.e. donations) made during the income year to endorsed DGRs. There are two elements which must be present in order to claim a taxdeduction: (a) it must be a gift; and (b) it must be made to a DGR.
The term "gift" is not defined in either the ITAA 1936 or 1997. As a consequence, it takes on its ordinary meaning.
On 20  For a gift to be a tax-deductible donation and claimed as an income tax deduction in personal income tax returns, the gift must usually have the following characteristics:  there is a transfer of the beneficial interest in property;  the transfer is made voluntarily;  the transfer arises by way of benefaction; and  no material benefit or advantage is received by the giver by way of return.
Generally, for a payment to be considered a gift it must be unfettered, that is, there must be no obligation to do anything in recognition of the gift and no expectation on the part of the donor to receive anything in return for the donation (i.e. no strings attached).
Where a payment constitutes a bona-fide gift, then the donor is entitled to claim the amount given as an income tax deduction under Division 30. In contrast, the following are not usually considered gifts:  purchase of raffle or art union tickets;  purchase of an item such as a mug, key ring or pen which is not merely a token that promotes the DGR or its activities;  the cost of attending a fundraising dinner, even if the cost exceeds the value of the dinner. However, there are new contribution rules that apply since 1 July 2004 for minor benefits made to DGRs;  payments to school building funds as an alternative to an increase in school fees;  membership fees (except to political parties); and  payments where the person has an understanding with the recipient that the payment will be used to provide a benefit to the donor.
However, since 1 July 2004 the government has allowed certain contributions, which do not fall under the strict definition of a gift, to be deductible. A deduction is now allowed where the donor receives a benefit in connection with the contribution, provided that certain conditions are met and the benefit does not exceed a specified limit. Broadly, this allows deductions for two separate types of contributions at a deductible gift recipient fund-raising event in Australia, namely:  contributions made in return for a right to participate in a fund-raising event (e.g. the purchase of a ticket to attend a charity ball, fete, dinner, performance or similar charitable fund-raising event); and  contributions made by way of consideration for the supply of goods and services for successful bidding at a charity auction that is conducted by a deductible gift recipient.

Categories of Deductible Gift Recipients
Since 1 July 2000, pursuant to Subdivision 30-BA of the ITAA 1997, the Commissioner of Taxation must endorse both Income Tax Exempt Charities (ITECs) and DGRs.
If a DGR is not endorsed by the Commissioner, donors will be unable to claim income tax deductions for gifts made since 1 July 2000 under Division 30 of the ITAA 1997.
Five new general categories of deductible gift recipient have been allowed since 1 July 2006:  disaster relief;  war memorials;  animal welfare;  charitable services; and  educational scholarships.
In addition to the above general categories of funds, authorities, institutions and organisations, gifts of $2 or more made to recipients specified in Sections 30-15 to 30-100 are also deductible to the donor.
However, these are only the general categories. This is not the full list of DGRs. Donors can check the status of a DGR by searching the Australian Business Register. 2 As at 31 October 2008 there were over 51,000 Tax Concession Charities but only about 20,000 qualify as Deductible Gift Recipients which can give tax deductible receipts.
Only certain types of gifts are specifically made tax-deductible under Division 30. These include:  gifts of $2 or more (money);  property which has been purchased by the donor less than 12 months before the gift was made;  property valued by the Commissioner as over $5,000;  trading stock disposed of outside the ordinary course of business;  cultural gifts, being property made under the Cultural Gifts Program;  cultural bequests, being property made under the Cultural Bequests Program; and  heritage gifts In order to claim the amount of their tax-deductible donation to a DGR, donors are required to keep records of their gifts. DGRs are not required by income tax law to issue receipts for deductible gifts, but most do, as the donor will need a receipt in order to substantiate the claim made.

New Philanthropic and Giving Taxation Initiatives
On 26 March 1999, the Prime Minister issued a press release announcing various income tax measures to encourage greater corporate and personal philanthropy in Australia. These new measures include:  establishment of prescribed private funds (PPFs);  tax deductibility for gifts of property over $5,000;  5-year averaging of donations;  deductions for workplace giving;  conservation covenants;  capital gains tax exemption under the Cultural Gifts Program;  deductions for fundraising dinners and similar events; and  new DGR category of health promotion charities.
Each of these taxation incentives is discussed below in more detail.
Further incentives have been suggested and developed by the Prime Minister"s Community Business Partnership since 1999. These incentives which involve the taxation regime have been rolled out gradually since 1999.

Establishment of Prescribed Private Funds (PPFs)
A PPF is a fund established by will or trust instrument with:  DGR status (i.e., gifts to it are deductible to the donor);  normally, income tax exempt status (i.e., its income is exempt from income tax); and  the ability to attract a variety of other Commonwealth, State and Territory tax and duty concessions.
There is no need for gifts to a PPF to be sought and received from the public and a PPF can be controlled by an individual, family or corporate group. This is a removal of a major barrier to philanthropy, as it was often difficult to satisfy the previous test of "public donations" before a fund would be endorsed as a DGR.
The PPFs prescribed by regulation 995-1.02 in respect of section 995-1 of the ITAA 1997 are listed in Table 2.
As at 14 November 2008, a total of 610 PPFs had been approved with 14 having ceased operation, but budget papers indicate that as at May 2009 there were over 900 PPFs in existence (refer Table 1). As at 30 June, 2006, the value of funds held by PPFs was $820.6 million with $342.6 million being received by them in donations in 2006.                         From 1 July 2001 changes to the legislation enabled donors to claim a tax deduction for gifts of property held by the donor and valued at more than $5,000 by the Commissioner of Taxation. This deduction was backdated to apply from 1 July 1999 and extends to property donated to approved environmental and heritage organisations. Previously, the deduction was only available where the property was purchased within 12 months of being donated.
Tax Laws Amendment (2007 Measures No. 2) Act 2007 made several amendments to the Income Tax Assessment Act 1997 to promote philanthropy. To promote philanthropic giving, the Government announced in the 2006-07 Budget that it would allow a tax deduction for the donation of certain publicly listed shares to deductible gift recipients, extending the current gift provisions.
The amendments allow a tax deduction for donations of shares in listed public companies, which were acquired at least 12 months before the donation, and have a market value of $5,000 or less. Donors can claim a deduction for the market value of the shares as at the day they made the gift.

c. 5 Year Averaging of Donations
Donors now have the ability to spread the following types of gifts over a period of up to 5 income years:  cash donations in excess of $5,000 (which took effect from 1 July 2003);  property valued by the Commissioner in excess of $5,000 (which took effect from 1 July 1999); and  cultural gifts made through the Cultural Gifts Program (which took effect from 1 July 1999).

d. Deductions for Workplace Giving
Workplace giving programs (which took effect from 1 July 2002) are designed to give employees the opportunity to make regular donations to a DGR through regular payroll deductions. Employees receive immediate tax benefits, as employers are able to reduce the amount of PAYG withholding tax from that employee"s pay.

e. Conservation Covenants
Certain types of conservation covenants over land, entered into on or after 1 July 2002, will be eligible for an income tax deduction and concessional capital gains tax treatment.

f. The Cultural Gifts Program -Capital Gains Tax Exemption
Since 1 July 1999, bequests of property and gifts of cultural property made through the Cultural Gifts Program are exempt from capital gains tax, thus maximising the appreciated value of these gifts for tax deduction purposes.

g. Deductions for Fundraising Dinners and Similar Events
Since 1 July 2004, individual taxpayers are, in certain circumstances, able to receive a tax deduction for "contributions" in the form of a ticket to a charity fundraising dinner. The deduction initially applied to contributions above $250, where the value of the benefit received (for example, a meal or entertainment) was no more than 10% of the total contribution or $100, whichever was less. The provision also relates to goods purchased at fundraising auctions.
Further changes were made from 1 January 2007 to reduce the minimum contribution threshold to $150 (previously $250), to allow a greater number of charities to use the measure for fundraising. The value of the minor benefit allowed was increased to 20 per cent of the gift or ticket pricebut not exceeding a value of $150 (previously 10% not exceeding $100).

h. Health Promotion Charities
A new DGR category known as Health Promotion Charities is entitled to the same benefits as Public Benevolent Institutions. This category commenced in 2002, but is back-dated to the 1997/98 year. It allows a tax deduction for gifts to charitable institutions whose principal activity is to promote the prevention or the control of behaviour that is harmful or abusive to human beings.

i. Donations to political parties and other candidates
Before 22   Australian disaster relief fundspublic funds for relief of people in distress as a result of a declared disaster which occurred in Australia;  animal welfare charitiescharitable institutions that provide short-term direct care and/or rehabilitate certain animals;  charitable services institutionscharitable institutions that would be public benevolent institutions but for their health promotion and/or harm prevention activities;  war memorial repair fundspublic funds established and maintained for the reconstruction or critical repair of a qualifying war memorial; and  developed country disaster relief fundspublic funds established by a public benevolent institution for relief of people in distress as a result of a declared disaster in a developed country.

k. Educational Scholarships
From 1 July 2006, a public fund established for charitable purposes is eligible for endorsement as a DGR by the Commissioner if its sole purpose is to provide money for scholarships, bursaries or prizes to which section 30-37 of the ITAA 1997 applies.
A scholarship, bursary or prize to which the section applies is one which:  may only be awarded to Australian citizens, or permanent residents of Australia, within the meaning of the Australian Citizenship Act 1948;  is open to individuals or groups of individuals throughout a region of at least 200,000 people, or throughout at least an entire state or territory;  promotes recipients' education in either or both of:  pre-school courses, primary courses, secondary courses or tertiary courses,  educational institutions overseas, by way of study of a component of one of the above courses; and  is awarded on merit or for reasons of equity (e.g. for students who are experiencing financial disadvantage or hardship).
Scholarships and bursaries are ongoing or one-off benefit payments for school fees, textbooks and related educational expenses such as uniforms or travel. A prize is an award of money or property that is usually conferred for reasons of merit such as academic achievement, but may also be for reasons of equity.

TAX-DEDUCTIBLE DONATIONS BY INDIVIDUAL TAXPAYERS
This section of the paper analyses the nature and extent of tax-deductible donations to DGRs claimed by Australian individual taxpayers in their 2007 income tax returns.
As mentioned in the Executive Summary, the information presented is based on the amount and type of tax-deductible donations made to DGRs and claimed by Australian individual taxpayers for the period 1 July 2006 to 30 June 2007. This information has been extracted mainly from the ATO's publication Taxation Statistics 2006-07. 4 The 2007 report is the latest report that has been made publicly available.
This study uses information based on published ATO material and represents only the extent of tax-deductible donations made to DGRs and claimed by Australian taxpayers at Item D9 Gifts or Donations in their individual income tax returns for the 2007 income year, and that have been processed by 31 October 2008. The data do not include corporate taxpayers as there is no provision on corporate taxpayers" tax returns to disclose gifts made to DGRs. Expenses such as raffles, sponsorships, fundraising purchases (e.g., sweets, tea towels, special events) or volunteering are generally not deductible as "gifts".
The Giving Australia Report used a more liberal definition of gift to arrive at an estimated total of giving at $11 billion for 2005 (excluding Tsunami giving of $300 million). The $11 billion total comprised $5.7 billion from adult Australians, $2 billion from charity gambling or special events and $3.3 billion from business sources. 5 4 The data represent information in tax returns for the 2006-07 year processed by the ATO as at 31 October 2008. It also includes some additional data supplied directly by the ATO to CPNS researchers. 5 Report available at http://www.fahcsia.gov.au/internet/factsinternet.nsf/communities/pmcbp_pubs.htm  1992-93 1993-94 1994-95 1995-96 1996-97 1997-98 1998-99 1999-

Summary and Discussion
Based on the data extracted from Table 1 in the Appendix (comprising Charts 1 to 6), our analysis reveals that Australians are claiming more tax-deductible donations to DGRs than ever before.
The amount of tax-deductible donations made and claimed by Australian taxpayers is impressive given the special event of the Tsunami. There has been a slight fall in the number of taxpayers claiming a tax deductible gift, but the amount claimed is still higher than recorded in the year of the Tsunami appeal and the subsequent year. This points to a quite robust philanthropic climate during this period.
For the first time, the ATO has provided data on gifts as a percentage of total income. More than half of the taxpayers claiming gifts fall in the bracket between 0-0.25% accounting for $133,193,806 or 7.06% of claimed deductible gifts. Those who claim more than 10% of their total income as deductible gifts (0.84% of total taxpayers) account for 37.83% of all deductible gifts.

Chart 10: Tax-Deductible Donation as a Percentage of Taxable Income by Gender
Based on the data extracted from Table 2 in the Appendix (forming the basis of Charts 7 to 10), our analysis reveals that there is little difference in the amount of tax-deductible giving between male and female Australian taxpayers.
Whilst more male taxpayers made and claimed tax-deductible donations to DGRs than female taxpayers (both in terms of total and average tax-deductible donations), female taxpayers donated more to DGRs when expressed as a percentage of their respective taxable incomes (0.37% for males and 0.39% for females).
In terms of donating taxpayers as a percentage of total taxpayers expressed by gender, our analysis revealed very little difference between the percentages of donating male taxpayers compared with donating female taxpayers.
In 2006-07, 35.82% of male taxpayers made and claimed tax-deductible donations to DGRs compared to 36.81% of female taxpayers. The combined average was 36.30%.

Individual Taxpayer Donations By State And Postcode Of Residence
For the second time we are able to drill down beyond state of residence to examine the postcode of residence for taxpayers who claimed a gift in 2006-07. On the CPNS website is a search tool for all Australian postcodes which will retrieve all the relevant deductible gift data for the years 2005-06 and 2006-07. This is available from http://www.bus.qut.edu.au/research/cpns/postcode.php Tables 5 and 6 in the Appendix (which form the basis for Tables 12 to 14 in this working paper) list the top five postcodes in each state by highest average claimed gift and highest total claimed gifts. There appears to be a relationship between the wealth of the taxpayers in each postcode and the total of the postcode"s gift deductions and total gifts claimed.

Chart 18: Tax-Deductible Donations as a Percentage of Taxable Income by Income Band
Based on the data extracted from Table 4 in the Appendix (forming the basis of Charts 15 to 18), our analysis supports the general contention that the greater the taxable income, the greater the amount of tax-deductible donations made to DGRs and claimed by Australian taxpayers; it also represents a greater percentage of their taxable incomes.
For those taxpayers with a taxable income between $6,001 and $10,000 the average claimed gift is $314.90 and 8.31% of taxpayers in this income band claim a gift. Total tax-deductible donations from all taxpayers in this band made up 0.32% of total taxable income from all taxpayers in this band.
In terms of taxpayers with taxable incomes of more than $1 million, a total of 4,675 taxpayers made and claimed tax-deductible donations to DGRs in 2007 totalling $226.96 million. This represented over 12.04% of the total tax-deductible donations made and claimed by individual Australian taxpayers in that particular income year.

Taxpayer Donations By Industry Classification
According to the ATO Statistics for 2006-07, 60% of total taxpayers were salary and wage earners and not carrying on a business under their own name (that is, not a company or trust etc). Table 6 in the Appendix to this paper (which forms the basis of Charts 19 to 22) contains data relating to the amount of tax-deductible donations made and claimed by individual Australian taxpayers carrying on a business as a sole trader in their 2007 income tax return according to their Australian New Zealand Standard Industry Classification (ANZSIC).
In the 2007 individual income tax return, an individual carrying on a business as a sole trader is required to complete the Business and Professional Items Schedule (comprising Items P1 to P19). Item P2 requires the taxpayer to provide a brief description of their main business or professional activity and classify the industry in which the business operates (Label A).
This industry classification is based on the ANZSIC system. The ANZSIC codes, numbered 1110 to 99070, form the basis of the following analysis. The ANZSIC code does not correlate to the taxpayer"s occupation code (Item 1, Label X). The following analysis is based on data collected from taxpayers who operate a business as a sole trader. It does not capture information on salary and wage earners (i.e. employees) who work within these industries, nor does it include business taxpayers operating through partnerships, trusts or companies.

Any person who does not enter an ANZSIC code in the Business and Professional Items
Schedule is automatically assumed to be a "salary and wage earner".
Furthermore, the category Subsidiary Return Income from P & T refers to taxpayers who are not engaged in businesses as sole traders, but receive distributions from partnerships and trusts (Item 11 Partnerships and Trusts in the 2007 tax return). This would include many small businesses structured as partnerships or discretionary trusts as well as distributions received by the individual from professional partnerships, such as accounting and law firms and medical practitioners, whose professional ethics and regulations prohibit them from incorporating.

Industry Chart 19: Total Tax-Deductible Donations by Industry
The next largest industry group that made and claimed tax-deductible donations to DGRs in 2007 (excluding "other") came from sole trader business taxpayers operating within the financial and insurance services industry. These taxpayers made and claimed tax-deductible donations of $291.13 million.
The next largest industry was sole trader business taxpayers operating in the agriculture, forestry and fishing industry. These taxpayers made and claimed tax-deductible donations to DGRs in 2007 totalling $87.47 million.
Chart 20: Percentage of Donating Taxpayers to Total Taxpayers by Industry shows the percentage of individual taxpayers who made and claimed tax-deductible donations by ANZSIC in 2006-07. The chart reveals that the highest percentage of donating taxpayers expressed as a percentage of total sole trader business taxpayers came from the taxpayers who nominated their industry as being from "investment income" with 46.97%. 6 The next highest were sole trader business taxpayers working in the professional, scientific and technical services industry with 39.83%.

Chart 20: Percentage of Donating Taxpayers to Total Taxpayers by Industry
At the opposite end of the scale, the industry with the least amount of donating taxpayers was sole trader business taxpayers engaged in the construction industry. Only 23.57% of sole trader business taxpayers working in this sector made and claimed tax-deductible donations to DGRs in 2007. The next lowest donors came from sole trader business taxpayers working within the accommodation and food services industry with 24.71% of sole trader business taxpayers claiming a tax-deductible donation.
In terms of average tax-deductible donations by industry code, Chart 21 Average Tax-Deductible Donation by Industry reveals that the highest average tax-deductible donations made and claimed by individual sole trader business taxpayers in 2006-07 came from taxpayers engaged in the agriculture, forestry and fishing industry. 7 These taxpayers made an average tax-deductible donation of $1,907.14. At the opposite end of the scale, the lowest average tax-deductible donations made and claimed in 2006-07 came from the construction industry with $219.54. Next lowest were sole trader business taxpayers engaged in the transport, postal and warehousing industry ($272.51).followed by sole trader business taxpayers involved in the administrative and support services industry with an average tax-deductible donation of $292.74 7 We have disregarded electricity, gas, water and waste service which is so small a sample to be unrepresentative. At the opposite end of the scale, the industry that made and claimed the least amount of taxdeductible donations to DGRs in 2007 (when expressed as a percentage of taxable income) were sole trader business taxpayers operating in the construction industry. These sole trader business taxpayers donated the equivalent of 0.13% of their taxable income. Tying for the second lowest tax-deductible donations as a percentage of taxable income were sole trader business taxpayers operating in the transport, postal and warehousing industry and those operating in the manufacturing industry; these two groups of sole traders donated the equivalent of 0.22% of their respective taxable incomes to DGRs in 2007.

Taxpayer Donations By Occupation
For the first time the ATO has made available data for wages and salary classified by occupation code of the taxpayer.
Occupation is taken from the personal tax return item 1. The occupation codes for 2006-07 are available at http://www.ato.gov.au/content/downloads/NAT1932_6_2007_bw.pdf and are based upon The Australian Standard Classification of Occupations produced by the Australian Bureau of Statistics (2 nd edition) 1997. There are nine major groups being:  managers and administrators,  professionals,  associate professionals;  tradespersons and related workers;  advanced clerical and service workers;  intermediate clerical, sales and service workers;  intermediate production and transport workers;  elementary clerical, sales and service workers; and  labourers and related workers.
Each major group has a number of sub groups. Table 8 in the appendix contains the data relating to these nine major groups of occupations. Professionals have 48.59% of their occupation claiming a gift representing 0.35% of taxable income with an average deductible gift of $429.00. They are significantly higher than any other occupation group (except for managers with an average gift of $1090) and closely followed by associate professionals who have an average gift of $275, being 0.23% of that group"s taxable income and a participation rate of 43.24%. These three occupation categories have the highest mean taxable income being $64,929 and %$55,120 respectively.
On the Centre"s website is a search tool for all occupations which will retrieve all the relevant deductible gift data for the year 2006-07 by occupation. This is available from http://www.bus.qut.edu.au/research/cpns/postcode.php Tables 15-18 below show the occupations with the highest average claimed gifts, highest total claimed gifts, highest percentage of claimed gifts against total income and highest percentage of participating taxpayers per occupation. Table 15 takes the top ten occupation groups by average gift. The first four occupations on the list have very high mean taxable incomes, all being in the top five occupations ranked by mean taxable income. The occupations of artists, and actors and related professionals appear to depart from this pattern being ranked sixth and eighth respectively while having mean incomes of about $40,000 each. Religious practitioners also have a very low taxable income average of about $30,000 but a relatively high average gift deduction.  Table 16 identifies the top ten occupations by total gifts. Company directors and managers top the list and have an average gift of $1,439 and $1,884 respectively. The second last category on the list comprising medical specialists also has a high average gift deduction being $1,681.    Lectureruniversity; Professor; University lecturer; University tutor 0.59% 10 General manager; Managing director 0.57% As a group, the average gift was $1,285, well above the total average and the percentage of participation was 43.18%, again well above the total taxpayer average.

INTERNATIONAL COMPARISONS OF CHARITABLE GIVING
It is not possible to make accurate comparisons of philanthropic giving between countries because there are no standard methods for collecting and reporting data, unlike the national accounts data which is subject to UN agreed standards. In recent times the generosity of Australians has been compared with the United States, Canada and the United Kingdom. For instance, the 1995 Industry Commission Report No. 45 entitled Charitable Organisations in Australia reported (at page 229): Even though comparisons of giving between countries are difficult, Australia compares poorly with the United States, both on a per capita basis and as a proportion of GDP Australians on average contribute almost $100 per year whereas Americans contribute over five times this amount.
However, to compare philanthropic donations using Tax Expenditure Tables across countries is not a particularly revealing activity. The way in which statistics are collected by the taxation authorities of various countries as well as the major differences in the taxation treatment of philanthropic gifts make meaningful comparisons difficult.
For example, when analysing taxation statistics in the United States, the figures include gifts by corporations, whereas in Australia they do not. In the US, only taxpayers who opt to file tax returns can claim gift deductions. In the case of corporations, donors may claim a gift tax deduction for no more than 10% of their taxable income in any year, but are able to carry forward any excess donations for up to five years. Gift deductibility is also available in the US for gifts to religious institutions, national and international amateur sports competitions and the advocacy of social change, which are almost entirely excluded in Australia. There are many other differences.
In Canada, like the US, there is a cap on the amount of donations that may be claimed in any one year, with the gift cap limited to 20% of a person"s taxable income, unless you are giving to the Canadian government and then it is unlimited.
The more common measure of giving which permits national comparisons is by percentage of Gross Domestic Product (GDP): total giving is divided by the country"s GDP. Noting the caveats and limitations we examine a number of jurisdictions below.
Research by the Charities Aid Foundation (CAF) in the UK found that the US is by far the most philanthropic nation, giving almost 1.7% of GDP to charitable causes. The average percentage of giving in the countries surveyed was 0.5% of GDP. Comparative figures included:  Briefing Paper, November 2006(using World Bank data 2005. Legacies, religious taxes (such as the German church taxes), and cash gifts directly given to the poor were not counted. The range of nonprofit organisations, donations to which can attract tax deductions, is much wider than that allowed in Australia and includes religious organisations and advocacy groups; almost all of the organisations we know as charitable or tax exempt in Australia would qualify.

United States Of America
There are limitations on the amount of the tax deduction that may be claimed. The percentage varies with the status of the donee, the donor and the type of property which makes for a very complex system of gift contributions.
In general, individuals may deduct:  up to 50% of their "adjusted gross income" (AGI) for donations to publicly supported charities;  up to 30% of AGI for donations to charities classified as private foundations;  up to 30% of AGI for donations of capital assets to publicly supported charities; and  up to 20% of AGI for donations of capital assets to privately supported foundations.
Only those taxpayers who itemise their deductions actually claim gift deductions, mostly those with taxable income over $US75,000. In addition, an individual retirement account (IRA) owner, aged 70½ or over, can directly transfer tax-free up to $100,000 per year to an eligible charitable organisation. This option was first available in tax years 2006 and 2007, but was extended in 2008 to the end of 2009. Eligible IRA owners can take advantage of this provision, regardless of whether they itemise their deductions.
On 2 April 2009, the US Senate rejected a proposal by President Obama to finance an overhaul of the nation"s health-care system by limiting the ability of the wealthy to take tax deductions for charitable contributions. The Senate unanimously approved an amendment to the pending budget plan that rejects the proposal to limit the size of itemised deductions that can be taken by those earning more than $250,000.
Corporations may generally deduct up to 10% of their taxable incomes, regardless of the status of the organisation and regardless of the type of property involved. Donations are also deductible for the purposes of gift and estate duty. It is possible for an individual"s tax base for gift and estate purposes to be reduced to zero by making donations to nonprofit organisations. In the United Kingdom, most organisations that come within the legal definition of charity are recipients of tax-deductible gifts. This includes religious organisations, educational institutions, the relief of poverty and sickness and other public benefit organisations that act in the community's interest. This is a much wider group of interests and activities compared to Australia's narrower conception of gift deductibility via Public Benevolent Institutions, philanthropic funds and specifically named institutions.

United Kingdom
A study (from Spain) 10 showing comparative giving per year in Europe compared with the US (expressed in Euros) supports the above findings:

Donation Differences from Australia
There are a number of differences in the donating environment between Canada and Australia, including: donations to a much wider range of entities being tax-deductible including charities such as churches and religious groups and a wider range of overseas charities; an individual"s donations are not deducted from their income, but are a tax credit; only a percentage of the donation is taken off actual tax paid; in any year individuals cannot claim more than 75% of their taxable income; donations made pursuant to a taxpayer"s will also generate a tax credit; a corporation can claim a deduction, but it is from taxable income as it is in Australia; these statistics do not include corporate giving; and all tax credits can be spread over five years.
Gifts to a registered charity by an individual may be deducted as a tax credit from an individual"s income tax, rather than a deduction from an individual"s assessable income as it is in Australia. A tax credit differs from a straight deduction from assessable income. It affects the taxpayer"s tax liability directly, rather than indirectly through the taxpayer"s taxable income. A percentage of the amount is set and this is the same for all taxpayers no matter what their tax bracket. Thus the taxpayer"s marginal rate of tax does not dictate the size of the subsidy the donor receives.
The Canadian tax credit rate is 15% of the first $200 and 29% for donations over $200. However, the maximum credit that an individual may claim is generally limited to a total of 75% of the taxpayer"s income for the year plus 25% of any taxable capital gain from making the gift. Unused credits in any year can be carried forward for up to five years. Special rules apply for gifts to the Crown, gifts to US charities, and gifts of certified cultural property.
In Canada, gifts to all charities (not just a specified class of charities such as gift deductible entities) receive tax benefits as well as gifts made in wills. This is much wider than permitted in Australia.
Donations by corporations are deductible by the corporation in computing its taxable income, which is similar to Australia. However, unlike Australia, there is a gift deduction cap of 75% of the corporation"s net income for the year.
The Canada Survey of Giving, Volunteering and Participating (2004) 11 found that over 22 million people aged 15 and over (85% of the population) made a financial donation to a charitable or other nonprofit organisation in the 12 month period of the study. The amount donated totalled $CAN8.9 billion with an average donation of $400. (See Table 24   h. For the first time the ATO has provided data by occupation code declared in an individual taxpayer"s return. There are a large number of taxpayers who do not declare their occupation or are classified as miscellaneous (3.4 m taxpayers).
Despite these limitations, the ATO statistics are one of the few places in which donation information is collected on a rigorous basis. All taxpayers are required to make a formal declaration at the end of their tax returns that the information contained therein is correct.
Under the system of self-assessment, the ATO generally treats the tax return lodged by a taxpayer as being correct when lodged.
However, the ATO has a wide-ranging audit program to confirm whether the details disclosed in taxpayers" income tax returns is correct or not. If the taxpayer has made a false or misleading statement or claimed an amount that cannot be substantiated, then the taxpayer is faced with the prospect of fines, penalties and interest charges.
The ATO Taxation Statistics also provide a useful trend as the information collated and published is collected annually on much the same basis. Other surveys are usually snapshots with different questions, methodology and definitions of what is a gift or donation.
However, it is considered that the results of this study will prove useful to fundraisers and in the development of fundraising strategies. Knowing where donors come from, and how much taxpayers within certain industries and specific occupations give, can assist DGRs to target fundraising strategies towards these donor groups. 13 The ATO revises its figures to take account of newly processed returns and adjustments for three years after initial release and this table reflects all revisions to April 2009.