International funders
Ubuntu Gale is a South African non-profit company. It is not a US 501(c)(3), an HMRC-recognised charity or a designated European public benefit institution — so a direct gift generally carries no relief in your jurisdiction. These are the routes that do work, and what each one requires of us.
Indicative only — not tax, legal or financial advice. Every figure on this page is a general statement of published law and codes, not an assessment of your circumstances. Tax and B-BBEE outcomes depend on your entity type, financial position, verification agency and the facts of the contribution. Confirm any figure with your own tax adviser, auditor and B-BBEE verification professional before you rely on it. Ubuntu Gale does not issue s18A receipts and does not hold public benefit organisation approval.
Last reviewed 2026-07-29
The short version
A deductible contribution must go to a US-organised donee. A foreign charity does not qualify directly, and the treaty exceptions cover only Canada, Mexico and Israel. Use a US 'friends of' 501(c)(3), a donor-advised fund, an equivalency determination under Rev. Proc. 2017-53, or expenditure responsibility.
Gift Aid and CTA 2010 s189 relief are restricted to HMRC-recognised charities, and EU/EEA charity recognition was withdrawn from 5 April 2024. Use a dual-qualified intermediary such as CAF or Prism the Gift Fund, or a UK 'friends of' charity.
Persche (CJEU C-318/07) prevents a member state from excluding a charity purely because it sits in another member state — it does not reach South Africa. Netherlands ANBI designation, German §10b relief and the Transnational Giving Europe network are the practical routes.
CAF America, GlobalGiving and the Myriad Alliance carry out donor due diligence, sanctions screening and onward granting. Build the handling fee and the vetting lead time into the plan rather than discovering them at disbursement.
The instrument can apply, but the outcome depends on facts we cannot assess for you — your entity type, targets, scorecard and verification.
Internal Revenue Code §170
Allows a deduction for charitable contributions, but only where the donee is a corporation, trust, community chest, fund or foundation created or organised in the United States or under the law of the United States or a State.
Who qualifies. US individual and corporate taxpayers giving to a US-organised donee. A foreign charity does not qualify directly, regardless of how charitable its work is. Treaty exceptions exist only for Canada, Mexico and Israel, and are themselves limited to income sourced in those countries.
(1) Give to a US 'friends of' organisation holding 501(c)(3) status, which exercises independent discretion and control over the onward grant. (2) Recommend a grant from a donor-advised fund whose sponsoring organisation conducts the international grantmaking. (3) For a private foundation, obtain an equivalency determination that Ubuntu Gale is the equivalent of a US public charity. (4) For a private foundation, exercise expenditure responsibility over the grant.
Ubuntu Gale is a South African non-profit company and is not a US 501(c)(3). A US donor cannot deduct a direct gift to Ubuntu Gale. We can support an equivalency determination or an expenditure-responsibility grant by supplying governing documents, financial statements and the reporting the route requires — and we will say clearly which route your adviser should use.
Finance Act 1990 (Gift Aid); Corporation Tax Act 2010, s189
Gift Aid allows a UK charity to reclaim basic-rate tax on an individual donation and lets a higher-rate taxpayer claim the difference. CTA 2010 s189 allows a UK company to deduct a qualifying charitable donation from its total profits.
Who qualifies. UK individual and corporate donors giving to a charity recognised by HMRC for UK tax purposes. Recognition of EU and EEA charities was withdrawn from 5 April 2024, so a charity established outside the UK can no longer qualify.
Because Ubuntu Gale is not an HMRC-recognised charity, neither Gift Aid nor s189 relief is available on a direct gift. The compliant route is to give through a dual-qualified intermediary — CAF (Charities Aid Foundation) and Prism the Gift Fund both operate this way — or through a UK 'friends of' charity that exercises its own discretion over the onward grant.
A direct gift from a UK donor to Ubuntu Gale attracts no UK relief. Give through a dual-qualified intermediary or a UK 'friends of' charity, and expect that intermediary to run its own due diligence on Ubuntu Gale before releasing funds. We will supply what they ask for.
Netherlands ANBI regime; Germany §10b EStG; Persche, CJEU C-318/07
Member states allow deductions for gifts to domestic charitable bodies, and — following the Court of Justice's decision in Persche (C-318/07) — may not refuse the deduction purely because the recipient is established in another member state, provided the donor can show the recipient satisfies the domestic conditions.
Who qualifies. Donors resident in member states with a charitable deduction. The Netherlands ANBI (algemeen nut beogende instelling) designation and the German §10b Einkommensteuergesetz deduction are the two most commonly used by international funders.
Persche establishes that a member state cannot categorically exclude a foreign charity, but the donor still carries the burden of demonstrating comparability to the domestic standard. In practice most funders use the Transnational Giving Europe network, which handles the comparability assessment between participating national partners, or apply for ANBI designation where the funding relationship justifies the effort.
Ubuntu Gale holds no European charitable designation. A European corporate funder should expect to give through a national partner foundation or an intermediary, and to run a comparability assessment first. We will supply governing and financial documents for that assessment.
Intermediary and reporting frameworks
Regulated intermediaries carry out donor due diligence, currency handling and onward granting so that a funder in one jurisdiction can support an organisation in another without either side improvising a compliance process. Separately, disclosure frameworks determine how a corporate funder reports the contribution.
Who qualifies. Any corporate or institutional funder giving across borders. CAF America, GlobalGiving and the Myriad Alliance (formerly the CAF global alliance network) are the routes most commonly used for grants into South Africa.
An intermediary gives the donor a domestically deductible gift and takes on the vetting, sanctions screening and onward-grant reporting. On the reporting side, a contribution to skills and enterprise development maps to CSRD social disclosures under ESRS S3 and S4, to the ISSB's IFRS S1 and S2 where the funder reports sustainability-related risk and opportunity, and to UN Sustainable Development Goals 4 (quality education), 8 (decent work and economic growth), 9 (industry, innovation and infrastructure), 10 (reduced inequalities) and 17 (partnerships for the goals).
Ubuntu Gale can be funded through an intermediary and will complete the vetting pack. We report delivery and outcome data that supports your own disclosure; we do not certify your compliance with CSRD, ISSB or any other framework, and we will not describe a pilot target as an achieved result.
What we supply
Every one of these routes puts a due-diligence burden on someone. Where the intermediary, foundation or practitioner needs it from us, we provide:
| Item | What it evidences |
|---|---|
| Memorandum of incorporation and CIPC registration | Legal existence, non-profit form and the objects the organisation is bound to. |
| Board list and governance policies | Who controls the organisation, and the conflict-of-interest and safeguarding rules they operate under. |
| Annual financial statements | Financial position and the basis for an equivalency or comparability assessment. |
| Programme descriptions and delivery evidence | That the charitable purpose described in a grant agreement is the one actually carried on. |
| Segregated-accounting confirmation | That grant funds can be accounted for separately, as expenditure responsibility requires. |
| Use-of-funds reporting to your schedule | The annual grantee reports a private foundation must obtain and attach to Form 990-PF. |
Indicative only — not tax, legal or financial advice. Every figure on this page is a general statement of published law and codes, not an assessment of your circumstances. Tax and B-BBEE outcomes depend on your entity type, financial position, verification agency and the facts of the contribution. Confirm any figure with your own tax adviser, auditor and B-BBEE verification professional before you rely on it. Ubuntu Gale does not issue s18A receipts and does not hold public benefit organisation approval.
Last reviewed 2026-07-29
Next step
The corporate application has a country field and a governance step — say there which intermediary or determination route you intend to use, and we will start assembling what it needs rather than waiting to be asked.
