The tax-free and rates-free charitable status of religions in this day and age is an anomaly which will eventually need resolving. As the proposal says:
“Despite this huge rise in the number of non-believers and increased focus on the importance of separation of church and state, most ‘secular’ governments continue to subsidise religious organisations; providing them with broad tax immunity (including any companies or corporations that they own), local rates exemptions and other entitlements. While the public expectation is that all religions are behaving as charities in the traditional sense (working to relieve poverty and advance the public good, etc.), the reality is that some churches are behaving more like corporations; stockpiling cash and buying external investments (putting aside for the moment the mansions, sports cars and diamond rings sported by bishops and ministers). The result of this tax break for the religious is that there is less money for education, healthcare, conservation and other core state functions that would benefit a nation as a whole.”
I think the problematic definition of a “Charity” it’s far larger than just religion, the definition hasn’t changed much since 1601; Charitable Uses Act of 1601.
The four heads (Education, Religion, Poverty and Other) that define what a Charity are outmoded and need revision to resemble something actually worthy of attracting tax relief.
Private schools, Private hospitals, Churches and breakfast cereal manufacturers (well one of them anyway!) – not to mention businesses and other elaborate legal structures all hiding behind these antiquated definitions.
Yet even if this problem were addressed, there is still no requirement in legislation whatsoever for a Charity to be charitable!
I attended an SDA church for a few months – they explained where the profits of Sanitarium went on a regular basis. From memory it was mostly to help people in developing countries get food and clean water.
Would you prefer their profits be taxed than spent on the poor?
Ministry of justice – I would prefer that money raised for genuine charitable purposes not be taxed. Unfortunately the religious provision distorts the meaning as it in no way provides for helping the poor. That is not a requirement. It provides only for dissemination and promotion of supernatural beliefs. And they must be supernatural.
Remove the religious status provision and money can still be given to the poor. It would be a more honest position for genuine religious charities to be in. Such bodies could still register under the other provisions.
The irrationality of the religious provision is that it requires supernatural beliefs and their promotion. This excludes secular organisations and is unfair on that basis. However, I don’t believe any organisation should get charitable tax exemption for promotion of their beliefs – supernatural or non-supernatural.
No I don’t have evidence for this other than my probably faulty memory. As I recall it Sanitarium gave through ADRA. That was more than 10 years ago and they may have changed since.
But consider the “music is my religion” guy. He can’t benefit from being a charity and neither can Sanitarium. All they can legally do is give away their profits.
If the “music is my religion” guy wants to give away the profits why would anyone want his religion’s profits to be taxed?
MoJ – I am well aware of the registration of the Humanist society. But this is under the sectors Education / training / research – not religion. It would be impossible for the Humanist society to register under the religion sector because it does not have or promote a supernatural belief. (and there is no sector for non-supernatural beleif).
However, your example does illustrate that it is possible for genuine charities to register without resorting to the religion sector justification. And consequently, under the current practice it is possible for organisations without a charitable bone in their bodies to register under the religious sector, and get tax and rates exemption. And it happens.
It would be more honest, and also more supportive of genuine charities, to remove the religious justification all together. Genuine charities would still survive.
I can’t see why humanists would be denied religious status. “Religious activities” is listed as one of the Humanist Society’s purposes on the register.
You say “supernatural” is a requirement but I can’t see any reference to “supernatural” in the legislation.
MoJ – because to qualify for the religious sector the goup must show a declared belief in the supernatural and evidence that it promotes that belief. It may, or may not, be in the legislation specifically but legal procedures has determined the qualifications.
To be charitable under this category, your organisation’s purpose must:
be for the benefit of a religion; and
aim to pass on the relevant religious faith to others.
The term “religion” includes many different faiths and belief systems (for example, Christianity, Judaism, Islam, Hinduism, and Buddhism). Generally, however, to be religious there needs to be:
… a belief in a supernatural being, thing, or principle
… an acceptance of conduct in order to give effect to that belief.
To “advance” religion, the faith must be passed on to others by spreading its message and taking positive steps to sustain and increase the religious belief.
For example, a court has said that religion is not advanced by an entirely enclosed religious order where the activities consist only of private prayer. (Alternatively, a court has said that offering public prayers for the soul of a deceased person gives benefit to all who hear them.)
“But consider the “music is my religion” guy. He can’t benefit from being a charity and neither can Sanitarium. All they can legally do is give away their profits.”
There is no requirement in legislation that profits, any profits must be given away.
So clearly Sanitarium and others can benefit (and do) from not paying tax – you should look at the stakeholders to see where benefits flow – not the poor and needy.
“When the owner of Christchurch Cathedral – Church Properties Trustees – professed in an article about the cathedral rebuild that it was “not wealthy”, Gousmett told North & South that according to its accounts it has assets of $180 million with a further $40 million to come from insurance and other expected income”
Sanitarium:
“Last year it made a surplus of $17 million, of which $4 million went to aid activities in the Pacific, $3 million to a home for the elderly and $10 million went back into the church – to be spent, says Gousmett, on who knows what”
Although not under the religious category, look at a “private” hospital here in Christchurch….
“Gousmett has asked why St George’s Hospital, with its charitable objective of altruistic nursing, reported payment to philanthropic causes of what amounted to 0.2 per cent of total income. So it treated 100 patients at subsidised rates and gave 50 mattresses away to the earthquake appeal, he says. “Well whoop-dee-do, their income last year was $44 million, so how generous was that?”
Well meaning people seem to think religion=charity.
If that’s true then let’s see the books.
What could be simpler?
After all, I’m sure nobody wants any religious group to be socking away money to create a financial empire under the cover of charitable status, right?
I have had a quick look at your blog – As you seem concerned for “justice” in NZ – where does this issue sit on your radar? and what political perspective do you take? (Right wing/centre/left wing or a composite)
Christopher
Politically I’m for justice and against injustice. Generally I’m for the things that most people across the political spectrum agree with… simple things like punishments for murder, assault, theft, fraud, etc. I’m also for victims being compensated by offenders. I’m for proportionate punishments. I’m against laws that threaten punishment where there is no wronged party. I’m for authority when it is justified (e.g. by ownership) and against unjustified authority. Something being good for the poor (left), good for the country (right) or good for freedom (libertarian) doesn’t itself justify legislation. And something being moral or immoral doesn’t itself justify legislation.
where does this issue sit on your radar?
Tax is not justified in this situation at all. Not for Humanists nor Scientologists nor Adventists.
1: the current system is an injustice because it treats people different according to belief. Supernaturalist don’t pay tax or rates (which means they are passing on costs to non-supernaturalists). While non-supernaturalists do pay tax and rates. Note – this has nothing to do with charity – simply belief and it’s advancement.
2: should individuals and groups be subsidised by tax exemption purely to have a belief, perform ceremonies related to that belief and advancing that belief. Again nothing to do with charity.
My position is that no belief should not privileged in this manner. )It is surely against our human rights legislation.) And that we should not be subsidising any belief – religious or non-religious.
MoJ – my quote was from the advice of the charities commission which is describing how the legislation is carried out. It is advice to people wishing to claim “charitable” status. And it is based on the legislation and it’s testing in courts.
It is the sort of comeback one gets if one attempts to use human rights legislation to argue against the current practice.
My understanding is that one usually gets told to attempt to establish ones argument in court – with the problem that preceding court decisions make success unlikely. Or to get the law itself changed to clarify.
Personally I think having a provision of advancement of religion being defined as charitable should be got rid of completely. It is not charitable by any sensible definition in the modern world.
“Tax is not justified in this situation at all. Not for Humanists nor Scientologists nor Adventists”
It appears you agree there should be a tax free benefit for “Charity” – so would you be in favour of removing the “Religious” component to Charitable status and leaving the educative, relief of poverty and other catergories?
MoJ – I agree comp-letely that humanists can advance their beliefs under the education” status – providing their actions qualify. Now why cannot religious organisations do the same thing?
In fact many do, and while many more insist on using the advancement of religion clause many of them could quite easily shift to one of the other more credible justifications if the advancement for relgion clause was removed. (Yes, some relgious organisations do actulaly do charitable work). For that reason I am a little sceptical of how much tax avoidance we could actulaly stop by removing that clause. For me it is more a human rights issue.
As for examples, organisations are continually being denied registration because they don’t qualify. Moere hopefully, Internal Affairs has been trying to weed out the more obvious examples of the system be used incorrectly. Greepeace was a recent example and I think a few have been stopped from using the advancement of religion justification. Mind you, I still think there are quite a few registered which should not be.
My position is that the activity of advancing beliefs (supernatural or not) is not a justification for taxing.
Hmm, seems simplistic.
Advancing beliefs doesn’t necessarily generate income.
When it does, why should advancing belief be exempt from any other income generating activity?
I agree comp-letely that humanists can advance their beliefs under the education” status – providing their actions qualify. Now why cannot religious organisations do the same thing?
Do you think supernaturalists could advance their supernatural beliefs under the education provisions?
Do you think supernaturalists could advance their supernatural beliefs under the education provisions? They can and do There are a number of theological schools and training schools for the religious who register under the education status. They probbaly also get other education benefits for themselves and their students in the process.
There are still a number of groups like Greenpeace and Family First (who I think were registered under the advancement of religion status) who should be removed. The NZ Health Trust is a clear example as it is an industry lobby group.
As for advancement of religion, there is nothing to stop that and removing that clause would in no way hinder it. It would just prevent this little trick being used to avoid taxation.
Don’t look for deep meaning in what I write – look for simple meanings.
All profits are untaxed… until they are taxed. 🙂
McDonalds could give away all of its profits to charity and thus avoid paying tax on its profits.
I said this because there is at least one false premise to this question:-
Advancing beliefs doesn’t necessarily generate income.
When it does, why should advancing belief be exempt from any other income generating activity?
Ah – I see, you’re confusing the tax benefits associated with donating funds to a Charity with those associated with the tax benefits a Charity has from income generation…
A privilege is by definition only available to a select group – but any company (e.g. McDonalds) can avoid paying tax by giving away their profits to charity.
You do realise that tax is payable on income only? No income, no tax.
Giving it away does not exempt you paying tax as there is nothing to tax! (a simplified interpretation of tax law)
An individual’s or company’s tax code remains the same.
Charities on the other hand attract tax free status from the IRD; the money the make is not taxable.
Importantly, they do not need to “give it away”, they can reinvest it to further grow their business.
Like the “music is my religion” guy anyone can start a charity.
If your minimum wage earner starts his own charity he can pay all of his money into it and pay no tax.
The untaxed money can then be kept in his charity’s bank account without paying tax on it.
The charity can invest this money, give it away or pay charity related expenses.
If he pays himself from the charity he then pays tax on that income.
Every individual and every organisation has the same opportunity.
Like the “music is my religion” guy anyone can start a company.
If your minimum wage earner starts his own company he can pay all of his money into it and pay no tax.
The untaxed money can then be kept in his company’s bank account without paying tax on it.
The company can invest this money, give it away or pay company related expenses.
If he pays himself from the company he then pays tax on that income.
Every individual and every organisation has the same opportunity.
Every individual and every organisation has the same opportunity.
Where’s the privilege?
As pointed out several times to you now, every individual and every organisation does not have the same opportunity.
If you choose not to acknowledge this, that’s your prerogative – but it comes across as ignorant (in the true sense of the word)
If however you attempt to persuade me with simple tautologies then that is not only is this ignorant but it makes you look stupid.
I would’ve thought that someone who professes to have an interest in “Justice” would have the courtesy of reading others comments before responding, as well as having the ability to present a rational argument.
Richard
My example was simplistic… if you want the minimum wage guy example to replicate the Sanitarium situation more completely his charity would have to start up or purchase a company.
Religion is not charity under the eyes of the law.
Here’s what Ken quoted from charities site…
For example, a court has said that religion is not advanced by an entirely enclosed religious order where the activities consist only of private prayer.
MoJ – simply not true. To register as a charity under the advancement of religion clause you must demonstrate a supernatural belief and orgnanise to promote it. Can’t see how Humanists or atheists could do this.
And they don’t. As has been pointed out to you already the Humanists in NZ do not register under advancement of religion but under educational clauses. That is genuine charitable classifications.
Your obscurantism on this issue is typical of what I have experienced many times before from those who clearly benefit from the unjust provision of advancement of relgion as charitable. Understandable because when one is defending financial interests the truth usually goes out the window.
Not saying you are in this group – just that you are using their arguments.
Ken
I just sent the question off to the Department of Internal Affairs (info@charities.govt.nz) about whether supernatural beliefs are a requirement for charity status under the Advancement of Religion provision.
MoJ, I suspect the reply from the DIA will refer you to the web page I cited. After all, that was provided to answer the questions of people who were considering registering under the advancement of religion clause.
Thank you for your query. Please note, we are unable to give pre-application advice and we recommend that you seek independent legal advice.
Case law has defined “religion” in terms of charity law as requiring “belief in a supernatural Being, Thing or Principle” (for example, see Centrepoint Community Growth Trust v Commissioner of Inland Revenue [1985] 1 NZLR 673 at 693).
However, we note that organisations such as the Humanist Society of New Zealand (Incorporated) and the New Zealand Humanist Charitable Trust are registered under the Charities Act 2005 (CC36074 and CC31395 respectively). In Barralet v Attorney General [1980] 3 All ER 918, the Court accepted a society devoted to advancing “the belief in the excellence of truth, love and beauty, but not belief in anything supernatural” as being charitable under the fourth head (“any other matter beneficial to the community”).
Finally, we note that we must consider each application on its merits and in light of its activities, and simply because similar organisations are registered under the Charities Act 2005 does not necessarily mean that an entity will qualify for registration.
I think that the DIA gave excellent examples that teased out the finer points of this area of law.
Take for example the case they cited; Centrepoint Community Growth Trust v Commissioner of Inland Revenue [1985] 1 NZLR 673 at 693. This is a good example explaining the requirement of the belief in a super natural being.
Notice that “religion” need not confer benefits on the public or wider community. Therefore the nature of such a group may be – (and will most likely be) “exclusive”
By satisfying the ‘Religious’ component, there is an automatic assumption (outdated I know) that the Charity concerned benefits society as a whole (Bollocks I think)
Compare this to the example of the Humanist Society of New Zealand (Incorporated) and the New Zealand Humanist Charitable Trust. By falling under the fourth head of ‘charity’ the purpose of these groups must have a sufficiently ‘public’ character, therefore the wider community and society (and therefore the taxpayer) will more likely benefit from the objects of the respective Charity. 🙂
Ken
I’m too busy to make comment ATM but here is the question I asked:-
I have been discussing the fairness of charity legislation on a blog and there is a question regarding the allowance of charity status for the advancement of religion.
Your website states the following :-
Advancement of religion
To be charitable under this category, your organisation’s purpose must –
be for the benefit of a religion and
ensure a religious faith is passed on to others.
The term “religion” includes many different faiths and belief systems (for example, Christianity, Judaism, Islam, Hinduism, and Buddhism).
Generally, to be religious there needs to be –
a belief in a supernatural being, thing, or principle, and
an acceptance of conduct in order to give effect to that belief.
To “advance” religion, the faith must be passed on to others by promoting it, spreading its message, or taking positive steps to sustain and increase the religious belief.
*************************
Some people have read this as meaning that belief in the supernatural is a requirement to get charity status under this provision.
Can a charity’s main purpose be the advancement of a belief system that does not include supernatural beliefs (e.g. Humanism or Objectivism) or is supernatural belief a requirement to get charity status under this provision?
OK, but doesn’t address my concern.
Can an organisation be registered as a charity purely on the grounds that it is a religious organisation?
No. Read my “semantic point” above
MoJ,
No one person or organisation can become registered simply on the grounds of who they are, so your ‘semantic point’ is utterly meaningless.
Have you not been reading this thread or are you trying to score points for stupidity?
But here is one for you MoJ as you somehow think there is no privilege for Sanitarium;
…I know you like simple explanations so forgive the hyperbole (or not, as the case may be)
Any individual (minimum wage earner) or company (McDonalds) must give away all of their profit so it can enjoy the same tax free benefit as a Religious Charity.
Yet the same Religious Charity is free to spend its profit on alcohol, cigarettes and prostitutes for the clergy (and other equally lawful pursuits),
Yet you think that there is no privilege to be had by the latter? Can you please explain or are you being overly pedantic here?
Christopher
I enjoy the discussion but I really need to do my taxes (and other things) so it’ll probably be Saturday before I reread this thread and make comment.
I just watched the Seven Sharp video. I find the supposed problem and solution are not clearly defined both in the video and here in this thread. (Sanitarium gets a lot of attention – not sure why exactly – but I think nobody would complain about it if it were owned by the SPCA.)
Is it wrong for a company to avoid tax by giving all of its profits to charity?
Is it wrong for charities to own companies?
Sanitarium gets a lot of attention – not sure why exactly – but I think nobody would complain about it if it were owned by the SPCA.
Really?
You are saying that can’t tell the difference between an organisation that is involved in the real world and one that is based on make-believe?
Is it wrong for a company to avoid tax by giving all of its profits to charity?
I think so. If they want to give away all of their profit, they are free to do so after tax.
Is it wrong for charities to own companies?
In my view certainly not, as long as the company pays tax on earnings as does any other commercial enterprise.
In my opinion the whole situation arises because the intent of the exception was probably to exempt donation to charity from taxation. Donations are freely given and not the product of commercial activity.
MoJ, I note you seem to avoid the issue of why the mere promotion of religion is regarded as a charitable activity or is a qualification to be registered as a charity.
If they want to give away all of their profit, they are free to do so after tax.
Really? That’s not been suggested by anyone else so far.
AFAIK any individual or company can make unlimited tax free donations to charity.
Would you have all charitable donations taxed?
MoJ, you are just being childishly disingenuous now. Of course anyone can give what they like to charity.
If the organisation they give to is registered as a charity they can claim the donations against their tax.
No one questions this. We only question the criteria for definition as a charity.
Why the hell should advancement of religion, requiring a supernatural belief and it’s promotion, ever be considered charitable?
You have tried to argue that advancement of religion also covers humanists and clearly it doesn’t. Surely you are now left with having to accept that there is an unfair practice operating. Either the advancement of any belief system, naturalistic as well as supernatural, should qualify for charitable status.
Or more justly none should. Charitable status should only be awarded for genuine charities. Remove the advancement of religion clause.
Ken
Richard says he thinks it is wrong for a company to avoid tax by giving all of its profits to charity.
So it’s not correct to say “No one questions this.”
I’m trying to establish the acceptance of these two propositions :-
1. It is not wrong for a company to avoid tax by giving all of its profits to charity.
2. It is not wrong for charities to own companies.
If these are accepted as true then the objections about Sanitariums supposed competitive advantage are nullified.
” If they want to give away all of their profit, they are free to do so after tax.”
Really? That’s not been suggested by anyone else so far.
AFAIK any individual or company can make unlimited tax free donations to charity.
Would you have all charitable donations taxed?
(patiently)
Donation =/= income from commercial activity.
I would have all income from commercial activity subject to tax. After it has been subject to tax people can do with it what they will, including gifting (donating) it to a charitable cause, that need not pay further tax on the gift or donation. Manufacturing goods for sale is a commercial activity. Buying goods such as Weetbix in a supermarket is a commercial transaction, it is a purchase, not an act of donation.
Nor in my view is promoting religion, the supernatural or make-believe a charitable activity. What is your view on this?
You have tried to argue that advancement of religion also covers humanists…
My argument was this :-
As I see it everyone is allowed to advance their beliefs in a tax exempt charity.
Humanists can advance their beliefs as “education.”
The letter from the DIA confirmed that you are correct about the legal interpretation of “religion” but the letter indicates that advancement of non-religious beliefs can be accepted under the “other” provision.
publishes “New Zealand Humanist”
issues a regular newsletter to members
broadcasts a regular Wellington Access Radio Programme
organises donations and awards
maintains a unique library of Humanist books and journals (based in Wellington)
organises seminars and gatherings of members and friends
maintains contact with national bodies with similar interests
makes representations to Government and public bodies on issues of general concern
is an affiliated member of the United Nations Association of NZ
Locally… Humanist branches meet regularly to
discuss and exchange ideas with people of like minds
hear speakers on Humanist philosophy, other belief systems, current political and social issues etc
organise projects such as the settlement of refugees, hospital visiting etc
Other activities include Social gatherings, picnics etc.
Seems to me that when religious interests are involved all honesty goes out the window.
MoJ you completely misrepresent Richard and you come across stupidly by trying to equate education to “advancing the interests of.” Making a noose for yourself in the process because why the hell would one need advancing religion if all charitable actions by a religous organisation can be covered by the the genuine charitable purposes, as they are with the humanists.
Why the hell do you advocate for such an outdated and undemocratic purpose? Are you benefitting from it it some way? Time for a declaration of interest, perhaps.
It would be helpful if you stuck to each issue independently.
1) Your fixation on the benefits that a Charity does or does not attract benefits as compared to other individual/companies
2) Advancing religion as a Charity and consequently the benefits that flow from this (see 1) )
Regarding 1), you seem to think that giving your profit/income away equates to the privilege of not having to pay tax. This ignores the fact that Charities need not a cent away to Charity and are free to spend the profit as they see fit.
Could you please address this apparent anomaly?
Regarding 2). You seem fixated on “Humanists” and think they are synonymous with advancing religion, forgetting the fact that Humanists (or any other non religious/poverty/education Charity) needs to benefit ALL of society. A Religious “Charity” need only benefit themselves….
Could you please tell me why advancing religion should be of benefit ONLY to themselves rather than the public/society as a whole?
And this statement is false if the income from commercial activity is donated.
Is trade not a commercial activity?
Commercial activity is not defined by where the proceeds wind up but by the nature of the activity. In the case of Sanitarium Food the activity is trade.
The Sanitarium Health & Wellbeing Company is the trading name of two sister food companies (Australian Health and Nutrition Association Ltd[1] and New Zealand Health Association Ltd).
Actually MoJ, your argument, as well as being disingenuous, highlights the dishonesty of the religious organisations calling their commercial operation charity and calling a commercial transaction an act of donation. I’m 100% positive that most purchasers of Sanitarium’s products, for example, don’t consider the transaction a donation.
Now, how about answering my earlier question and Ken’s question as to if you have any interest in any religious charity or other charity.
Here is my question for the third time:
Nor in my view is promoting religion, the supernatural or make-believe a charitable activity. What is your view on this?
How ’bout this moj,
sanitarium could give away all of its profits to a “real” charity so that all of society could benefit?
…. What I hear you say?…there is more chance of a camel passing through an eye of a needle?
Christopher
If Sanitarium were required by law to give its profits to “real” charities would that satisfy all of your objections to its existence and charity status?
If Sanitarium were required by law to give its profits to “real” charities would that satisfy all of your objections to its existence and charity status?
It would be a start.
Better than giving away Weetbix.
I’d like to go further and re-examine the whole rationale of allowing the promotion of religion as reason to qualify an organisation (or even an individual) as a charitable entity. A point that MoJ is loudly silent on.
Open Parachute 
I think the problematic definition of a “Charity” it’s far larger than just religion, the definition hasn’t changed much since 1601; Charitable Uses Act of 1601.
The four heads (Education, Religion, Poverty and Other) that define what a Charity are outmoded and need revision to resemble something actually worthy of attracting tax relief.
Private schools, Private hospitals, Churches and breakfast cereal manufacturers (well one of them anyway!) – not to mention businesses and other elaborate legal structures all hiding behind these antiquated definitions.
Yet even if this problem were addressed, there is still no requirement in legislation whatsoever for a Charity to be charitable!
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I doubt the “music is my religion” guy will be financially any better off as a charity than he would as a company or sole trader.
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Maybe. But seems he could be a company or sole grader and still get charitable tax free status as he current law is interpreted.
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I think charity status would only be of benefit to him if he gives his profits away.
Although it would really benefit those he’s giving to… but any recipient would still have to declare the gift and be taxed on it.
Charity status avoids a double tax scenario.
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Like Sanitarium?
>
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Yes, like sanitarium.
I attended an SDA church for a few months – they explained where the profits of Sanitarium went on a regular basis. From memory it was mostly to help people in developing countries get food and clean water.
Would you prefer their profits be taxed than spent on the poor?
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Hi Ministyofjustice,
Part of the problem with “Charitible Status” is the lack of transparency.
You say that Santitarium gave most of its profits to developing countries? Do you have any evidence for this?
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Ministry of justice – I would prefer that money raised for genuine charitable purposes not be taxed. Unfortunately the religious provision distorts the meaning as it in no way provides for helping the poor. That is not a requirement. It provides only for dissemination and promotion of supernatural beliefs. And they must be supernatural.
Remove the religious status provision and money can still be given to the poor. It would be a more honest position for genuine religious charities to be in. Such bodies could still register under the other provisions.
The irrationality of the religious provision is that it requires supernatural beliefs and their promotion. This excludes secular organisations and is unfair on that basis. However, I don’t believe any organisation should get charitable tax exemption for promotion of their beliefs – supernatural or non-supernatural.
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Hi Christopher,
No I don’t have evidence for this other than my probably faulty memory. As I recall it Sanitarium gave through ADRA. That was more than 10 years ago and they may have changed since.
But consider the “music is my religion” guy. He can’t benefit from being a charity and neither can Sanitarium. All they can legally do is give away their profits.
If the “music is my religion” guy wants to give away the profits why would anyone want his religion’s profits to be taxed?
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Ken
From the Humanist Society Site
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MoJ – I am well aware of the registration of the Humanist society. But this is under the sectors Education / training / research – not religion. It would be impossible for the Humanist society to register under the religion sector because it does not have or promote a supernatural belief. (and there is no sector for non-supernatural beleif).
However, your example does illustrate that it is possible for genuine charities to register without resorting to the religion sector justification. And consequently, under the current practice it is possible for organisations without a charitable bone in their bodies to register under the religious sector, and get tax and rates exemption. And it happens.
It would be more honest, and also more supportive of genuine charities, to remove the religious justification all together. Genuine charities would still survive.
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I can’t see why humanists would be denied religious status. “Religious activities” is listed as one of the Humanist Society’s purposes on the register.
You say “supernatural” is a requirement but I can’t see any reference to “supernatural” in the legislation.
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MoJ – because to qualify for the religious sector the goup must show a declared belief in the supernatural and evidence that it promotes that belief. It may, or may not, be in the legislation specifically but legal procedures has determined the qualifications.
From the Charities website:
Advancement of religion
To be charitable under this category, your organisation’s purpose must:
The term “religion” includes many different faiths and belief systems (for example, Christianity, Judaism, Islam, Hinduism, and Buddhism). Generally, however, to be religious there needs to be:
To “advance” religion, the faith must be passed on to others by spreading its message and taking positive steps to sustain and increase the religious belief.
For example, a court has said that religion is not advanced by an entirely enclosed religious order where the activities consist only of private prayer. (Alternatively, a court has said that offering public prayers for the soul of a deceased person gives benefit to all who hear them.)
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Thanks for replying ministryofjusticenz
I have issue when you say;
“But consider the “music is my religion” guy. He can’t benefit from being a charity and neither can Sanitarium. All they can legally do is give away their profits.”
There is no requirement in legislation that profits, any profits must be given away.
So clearly Sanitarium and others can benefit (and do) from not paying tax – you should look at the stakeholders to see where benefits flow – not the poor and needy.
Have a read here;
http://www.nzherald.co.nz/nz/news/article.cfm?c_id=1&objectid=10893671
Christchurch Cathedral
“When the owner of Christchurch Cathedral – Church Properties Trustees – professed in an article about the cathedral rebuild that it was “not wealthy”, Gousmett told North & South that according to its accounts it has assets of $180 million with a further $40 million to come from insurance and other expected income”
Sanitarium:
“Last year it made a surplus of $17 million, of which $4 million went to aid activities in the Pacific, $3 million to a home for the elderly and $10 million went back into the church – to be spent, says Gousmett, on who knows what”
Although not under the religious category, look at a “private” hospital here in Christchurch….
“Gousmett has asked why St George’s Hospital, with its charitable objective of altruistic nursing, reported payment to philanthropic causes of what amounted to 0.2 per cent of total income. So it treated 100 patients at subsidised rates and gave 50 mattresses away to the earthquake appeal, he says. “Well whoop-dee-do, their income last year was $44 million, so how generous was that?”
I’d be interested in your thoughts.
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Well meaning people seem to think religion=charity.
If that’s true then let’s see the books.
What could be simpler?
After all, I’m sure nobody wants any religious group to be socking away money to create a financial empire under the cover of charitable status, right?
Mother Teresa: DEAFANATLY NOT A SAINT
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Hi ministryofjusticenz,
I have had a quick look at your blog – As you seem concerned for “justice” in NZ – where does this issue sit on your radar? and what political perspective do you take? (Right wing/centre/left wing or a composite)
Cheers
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Christopher
Politically I’m for justice and against injustice. Generally I’m for the things that most people across the political spectrum agree with… simple things like punishments for murder, assault, theft, fraud, etc. I’m also for victims being compensated by offenders. I’m for proportionate punishments. I’m against laws that threaten punishment where there is no wronged party. I’m for authority when it is justified (e.g. by ownership) and against unjustified authority. Something being good for the poor (left), good for the country (right) or good for freedom (libertarian) doesn’t itself justify legislation. And something being moral or immoral doesn’t itself justify legislation.
Tax is not justified in this situation at all. Not for Humanists nor Scientologists nor Adventists.
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Ken
I don’t think you read that correctly – it say “generally” – and it’s a description on website not a piece of legislation.
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I guess there are two issues here.
1: the current system is an injustice because it treats people different according to belief. Supernaturalist don’t pay tax or rates (which means they are passing on costs to non-supernaturalists). While non-supernaturalists do pay tax and rates. Note – this has nothing to do with charity – simply belief and it’s advancement.
2: should individuals and groups be subsidised by tax exemption purely to have a belief, perform ceremonies related to that belief and advancing that belief. Again nothing to do with charity.
My position is that no belief should not privileged in this manner. )It is surely against our human rights legislation.) And that we should not be subsidising any belief – religious or non-religious.
The current injustice is historical and archaic.
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MoJ – my quote was from the advice of the charities commission which is describing how the legislation is carried out. It is advice to people wishing to claim “charitable” status. And it is based on the legislation and it’s testing in courts.
It is the sort of comeback one gets if one attempts to use human rights legislation to argue against the current practice.
My understanding is that one usually gets told to attempt to establish ones argument in court – with the problem that preceding court decisions make success unlikely. Or to get the law itself changed to clarify.
Personally I think having a provision of advancement of religion being defined as charitable should be got rid of completely. It is not charitable by any sensible definition in the modern world.
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As I see it everyone is allowed to advance their beliefs in a tax exempt charity.
Humanists can advance their beliefs as “education.”
Do you have an example of anyone being refused charity status?
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Tax is not justified in this situation at all. Not for Humanists nor Scientologists nor Adventists.
Sorry, I find this unclear. Does it simply read that in your view taxing any charity is unjustified?
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As I see it everyone is allowed to advance their beliefs in a tax exempt charity.
1) What has superstition got to do with the administration of charity?
2) How do you safeguard against those using charity as a front for an agenda to push their superstition?
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Cheers MoJ,
I am more confused than ever now!
But staying on the subject of Charity.
you said;
“Tax is not justified in this situation at all. Not for Humanists nor Scientologists nor Adventists”
It appears you agree there should be a tax free benefit for “Charity” – so would you be in favour of removing the “Religious” component to Charitable status and leaving the educative, relief of poverty and other catergories?
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MoJ – I agree comp-letely that humanists can advance their beliefs under the education” status – providing their actions qualify. Now why cannot religious organisations do the same thing?
In fact many do, and while many more insist on using the advancement of religion clause many of them could quite easily shift to one of the other more credible justifications if the advancement for relgion clause was removed. (Yes, some relgious organisations do actulaly do charitable work). For that reason I am a little sceptical of how much tax avoidance we could actulaly stop by removing that clause. For me it is more a human rights issue.
As for examples, organisations are continually being denied registration because they don’t qualify. Moere hopefully, Internal Affairs has been trying to weed out the more obvious examples of the system be used incorrectly. Greepeace was a recent example and I think a few have been stopped from using the advancement of religion justification. Mind you, I still think there are quite a few registered which should not be.
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Richard
My position is that the activity of advancing beliefs (supernatural or not) is not a justification for taxing.
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My position is that the activity of advancing beliefs (supernatural or not) is not a justification for taxing.
Hmm, seems simplistic.
Advancing beliefs doesn’t necessarily generate income.
When it does, why should advancing belief be exempt from any other income generating activity?
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Typo:
When it does, why should advancing belief be exempt from taxation as required by any other income generating activity?
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There’s no barrier to stop McDonalds from giving all of it untaxed profits to charity.
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From my perspective the politics of others seems convoluted.
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Ken
Do you think supernaturalists could advance their supernatural beliefs under the education provisions?
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Ken
I imagine Greenpeace were denied because they are a political lobby group. That’s why family first were denied charity status.
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Do you think supernaturalists could advance their supernatural beliefs under the education provisions? They can and do There are a number of theological schools and training schools for the religious who register under the education status. They probbaly also get other education benefits for themselves and their students in the process.
There are still a number of groups like Greenpeace and Family First (who I think were registered under the advancement of religion status) who should be removed. The NZ Health Trust is a clear example as it is an industry lobby group.
As for advancement of religion, there is nothing to stop that and removing that clause would in no way hinder it. It would just prevent this little trick being used to avoid taxation.
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The Humanist Society runs a radio program – this is currently a charitable activity promoting humanism (they might prefer to call it “education”)
Do you think this should be a tax exempt activity or not?
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“There’s no barrier to stop McDonalds from giving all of it untaxed profits to charity”
McDonalds has untaxed profits? Now I’m really confused! 🙂
PS: How do you italicize text in a post?
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There’s no barrier to stop McDonalds from giving all of it untaxed profits to charity.
That appears to be a deepity.
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PS: How do you italicize text in a post?
one of these , insert quote and close with,
use “b” for bold, “blockquote” for inserted quote, others hypertext codes available too, see wikipedia
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damn thought that might happen, its hard to explain when any example is treated as attempt to use html code.
[i] italic quote [/i] [b[ bold type [/b]
etc , but use < instead of [
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Thanks Richard
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Test
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Don’t look for deep meaning in what I write – look for simple meanings.
All profits are untaxed… until they are taxed. 🙂
McDonalds could give away all of its profits to charity and thus avoid paying tax on its profits.
I said this because there is at least one false premise to this question:-
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Deepity is as deepity does, arguably more a case of calling squirrel!!! .
Still irrelevant.
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Hi MoJ,
Ah – I see, you’re confusing the tax benefits associated with donating funds to a Charity with those associated with the tax benefits a Charity has from income generation…
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Christopher
I agree that those things are being conflated.
Do you agree with me that Sanitarium has no tax privilege?
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Richard
If you think my perspective consists of simplistic deepities intellectually equivalent to shouting “squirrel” then just ignore me.
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MoJ,
No
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Moj,
So…how is not paying any income tax not a tax privilege?
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A privilege is by definition only available to a select group – but any company (e.g. McDonalds) can avoid paying tax by giving away their profits to charity.
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Do you agree with me that Sanitarium is not privileged?
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MoJ,
A privilege is by definition only available to a select group
So….how does this work for someone on minimum wage?
I don’t want to appear rude, but you haven’t answered my question…how is not paying any income tax not a tax privilege?
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Christopher
I did answer your question. Something available to all is not a privilege by definition.
(Presuming this applies to individuals) they’d have to give all their income to charity.
Would they then have a tax privilege? 🙂 I say no.
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MoJ,
You are being silly now aren’t you!
You do realise that tax is payable on income only? No income, no tax.
Giving it away does not exempt you paying tax as there is nothing to tax! (a simplified interpretation of tax law)
An individual’s or company’s tax code remains the same.
Charities on the other hand attract tax free status from the IRD; the money the make is not taxable.
Importantly, they do not need to “give it away”, they can reinvest it to further grow their business.
http://www.nzherald.co.nz/business/news/article.cfm?c_id=3&objectid=10816412
So by your definition they are privileged.
So have you got it wrong?
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Christopher
As I understand it…
Like the “music is my religion” guy anyone can start a charity.
If your minimum wage earner starts his own charity he can pay all of his money into it and pay no tax.
The untaxed money can then be kept in his charity’s bank account without paying tax on it.
The charity can invest this money, give it away or pay charity related expenses.
If he pays himself from the charity he then pays tax on that income.
Every individual and every organisation has the same opportunity.
Where’s the privilege?
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The world according to MoJ
Like the “music is my religion” guy anyone can start a company.
If your minimum wage earner starts his own company he can pay all of his money into it and pay no tax.
The untaxed money can then be kept in his company’s bank account without paying tax on it.
The company can invest this money, give it away or pay company related expenses.
If he pays himself from the company he then pays tax on that income.
Every individual and every organisation has the same opportunity.
Yeah, nah
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MoJ,
Like the “music is my religion” guy anyone can start a charity.
You don’t seem to be reading this post…anyone cannot “start” a charity…read my first post https://openparachute.wordpress.com/2014/04/13/an-outdated-tax-anomaly-charitable-status-of-relgion/#comment-54568
Every individual and every organisation has the same opportunity.
Where’s the privilege?
As pointed out several times to you now, every individual and every organisation does not have the same opportunity.
If you choose not to acknowledge this, that’s your prerogative – but it comes across as ignorant (in the true sense of the word)
If however you attempt to persuade me with simple tautologies then that is not only is this ignorant but it makes you look stupid.
I would’ve thought that someone who professes to have an interest in “Justice” would have the courtesy of reading others comments before responding, as well as having the ability to present a rational argument.
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Richard
My example was simplistic… if you want the minimum wage guy example to replicate the Sanitarium situation more completely his charity would have to start up or purchase a company.
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Religion = charity, if the religion so desires (in eyes of our law)
But charity =/= company even if they both waddle and quack.
MoJ would have us believe this is not privilege.
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Religion is not charity under the eyes of the law.
Here’s what Ken quoted from charities site…
Advancing religion is considered charity.
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Handclap for the semantic point.
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Advancing religion = charity, if the religion advancing it so desires (in eyes of our law)
But a charity =/= a company even when they both waddle and quack.
MoJ would have us believe both are not privilege.
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Richard
Anyone can advance their religion as a charity even Humanists and Scientologists. On this point there is no privilege.
I’m not sure what your charity=/= a company comment means.
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Anyone can advance their religion as a charity even Humanists and Scientologists. On this point there is no privilege.
mmm….are you sure MoJ?
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Fairly sure.
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MoJ – simply not true. To register as a charity under the advancement of religion clause you must demonstrate a supernatural belief and orgnanise to promote it. Can’t see how Humanists or atheists could do this.
And they don’t. As has been pointed out to you already the Humanists in NZ do not register under advancement of religion but under educational clauses. That is genuine charitable classifications.
Your obscurantism on this issue is typical of what I have experienced many times before from those who clearly benefit from the unjust provision of advancement of relgion as charitable. Understandable because when one is defending financial interests the truth usually goes out the window.
Not saying you are in this group – just that you are using their arguments.
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It’s ludicrous to classify financial gain for purpose of advancement of belief in the supernatural as being a charitable activity.
I’ve yet to hear a valid argument for it.
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Ken
I just sent the question off to the Department of Internal Affairs (info@charities.govt.nz) about whether supernatural beliefs are a requirement for charity status under the Advancement of Religion provision.
I’ll post the reply here if I get one.
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MoJ, I suspect the reply from the DIA will refer you to the web page I cited. After all, that was provided to answer the questions of people who were considering registering under the advancement of religion clause.
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OK, but doesn’t address my concern.
Can an organisation be registered as a charity purely on the grounds that it is a religious organisation?
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MoJ – could you please give us the text of your query to the FiA so we can see the specifics of York query and relate this to the answer?
Thanks.
As far as I can tell the answer confirms what I have been telling you.
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The question is…does moj think he got it right or wrong?
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Thanks for posting MoJ,
I think that the DIA gave excellent examples that teased out the finer points of this area of law.
Take for example the case they cited; Centrepoint Community Growth Trust v Commissioner of Inland Revenue [1985] 1 NZLR 673 at 693. This is a good example explaining the requirement of the belief in a super natural being.
Notice that “religion” need not confer benefits on the public or wider community. Therefore the nature of such a group may be – (and will most likely be) “exclusive”
By satisfying the ‘Religious’ component, there is an automatic assumption (outdated I know) that the Charity concerned benefits society as a whole (Bollocks I think)
Compare this to the example of the Humanist Society of New Zealand (Incorporated) and the New Zealand Humanist Charitable Trust. By falling under the fourth head of ‘charity’ the purpose of these groups must have a sufficiently ‘public’ character, therefore the wider community and society (and therefore the taxpayer) will more likely benefit from the objects of the respective Charity. 🙂
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Ken
I’m too busy to make comment ATM but here is the question I asked:-
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Richard
No. Read my “semantic point” above.
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OK, but doesn’t address my concern.
Can an organisation be registered as a charity purely on the grounds that it is a religious organisation?
No. Read my “semantic point” above
MoJ,
No one person or organisation can become registered simply on the grounds of who they are, so your ‘semantic point’ is utterly meaningless.
Have you not been reading this thread or are you trying to score points for stupidity?
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Some people have read this as meaning that belief in the supernatural is a requirement to get charity status under this provision
Moj, I know you asked Ken this question, but this is wasting his time. I hope you don’t mind me replying Ken.
I have answered you here https://openparachute.wordpress.com/2014/04/13/an-outdated-tax-anomaly-charitable-status-of-relgion/#comment-54568
and I have repeated this here; https://openparachute.wordpress.com/2014/04/13/an-outdated-tax-anomaly-charitable-status-of-relgion/#comment-55014
But here is one for you MoJ as you somehow think there is no privilege for Sanitarium;
…I know you like simple explanations so forgive the hyperbole (or not, as the case may be)
Any individual (minimum wage earner) or company (McDonalds) must give away all of their profit so it can enjoy the same tax free benefit as a Religious Charity.
Yet the same Religious Charity is free to spend its profit on alcohol, cigarettes and prostitutes for the clergy (and other equally lawful pursuits),
Yet you think that there is no privilege to be had by the latter? Can you please explain or are you being overly pedantic here?
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Christopher
I enjoy the discussion but I really need to do my taxes (and other things) so it’ll probably be Saturday before I reread this thread and make comment.
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Moj, where are you? You said you would be back…I was quite enjoying your diversions
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You’re prrobably still doing your taxes…
Have a look at this, Seven Sharp Wednesday night, directly on point
http://tvnz.co.nz/seven-sharp/your-favourite-things-getting-big-tax-break-why-video-5945285
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Yeah, I am still doing my taxes.
I just watched the Seven Sharp video. I find the supposed problem and solution are not clearly defined both in the video and here in this thread. (Sanitarium gets a lot of attention – not sure why exactly – but I think nobody would complain about it if it were owned by the SPCA.)
Is it wrong for a company to avoid tax by giving all of its profits to charity?
Is it wrong for charities to own companies?
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Sanitarium gets a lot of attention – not sure why exactly – but I think nobody would complain about it if it were owned by the SPCA.
Really?
You are saying that can’t tell the difference between an organisation that is involved in the real world and one that is based on make-believe?
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Is it wrong for a company to avoid tax by giving all of its profits to charity?
I think so. If they want to give away all of their profit, they are free to do so after tax.
Is it wrong for charities to own companies?
In my view certainly not, as long as the company pays tax on earnings as does any other commercial enterprise.
In my opinion the whole situation arises because the intent of the exception was probably to exempt donation to charity from taxation. Donations are freely given and not the product of commercial activity.
MoJ, I note you seem to avoid the issue of why the mere promotion of religion is regarded as a charitable activity or is a qualification to be registered as a charity.
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I find the supposed problem and solution….
“Supposed” problem? What a confused, tiny world you live in.
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Richard
Really? That’s not been suggested by anyone else so far.
AFAIK any individual or company can make unlimited tax free donations to charity.
Would you have all charitable donations taxed?
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Cedric
The mouth speaks from the overflow of the heart.
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MoJ, you are just being childishly disingenuous now. Of course anyone can give what they like to charity.
If the organisation they give to is registered as a charity they can claim the donations against their tax.
No one questions this. We only question the criteria for definition as a charity.
Why the hell should advancement of religion, requiring a supernatural belief and it’s promotion, ever be considered charitable?
You have tried to argue that advancement of religion also covers humanists and clearly it doesn’t. Surely you are now left with having to accept that there is an unfair practice operating. Either the advancement of any belief system, naturalistic as well as supernatural, should qualify for charitable status.
Or more justly none should. Charitable status should only be awarded for genuine charities. Remove the advancement of religion clause.
>
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Ken
Richard says he thinks it is wrong for a company to avoid tax by giving all of its profits to charity.
So it’s not correct to say “No one questions this.”
I’m trying to establish the acceptance of these two propositions :-
1. It is not wrong for a company to avoid tax by giving all of its profits to charity.
2. It is not wrong for charities to own companies.
If these are accepted as true then the objections about Sanitariums supposed competitive advantage are nullified.
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Moj, you are an interesting one aren’t you! I wonder whether you are having a quiet laugh to yourself or whether you a being serious ?
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” If they want to give away all of their profit, they are free to do so after tax.”
Really? That’s not been suggested by anyone else so far.
AFAIK any individual or company can make unlimited tax free donations to charity.
Would you have all charitable donations taxed?
(patiently)
Donation =/= income from commercial activity.
I would have all income from commercial activity subject to tax. After it has been subject to tax people can do with it what they will, including gifting (donating) it to a charitable cause, that need not pay further tax on the gift or donation. Manufacturing goods for sale is a commercial activity. Buying goods such as Weetbix in a supermarket is a commercial transaction, it is a purchase, not an act of donation.
Nor in my view is promoting religion, the supernatural or make-believe a charitable activity. What is your view on this?
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Ken
My argument was this :-
The letter from the DIA confirmed that you are correct about the legal interpretation of “religion” but the letter indicates that advancement of non-religious beliefs can be accepted under the “other” provision.
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What the humanist society does:-
Outreach and fellowship.
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Seems to me that when religious interests are involved all honesty goes out the window.
MoJ you completely misrepresent Richard and you come across stupidly by trying to equate education to “advancing the interests of.” Making a noose for yourself in the process because why the hell would one need advancing religion if all charitable actions by a religous organisation can be covered by the the genuine charitable purposes, as they are with the humanists.
Why the hell do you advocate for such an outdated and undemocratic purpose? Are you benefitting from it it some way? Time for a declaration of interest, perhaps.
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Richard
Income – Expenses – Donations = Taxable Profit
You are currently free to make donations before tax.
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Moj,
There seem to be several issue going on here.
It would be helpful if you stuck to each issue independently.
1) Your fixation on the benefits that a Charity does or does not attract benefits as compared to other individual/companies
2) Advancing religion as a Charity and consequently the benefits that flow from this (see 1) )
Regarding 1), you seem to think that giving your profit/income away equates to the privilege of not having to pay tax. This ignores the fact that Charities need not a cent away to Charity and are free to spend the profit as they see fit.
Could you please address this apparent anomaly?
Regarding 2). You seem fixated on “Humanists” and think they are synonymous with advancing religion, forgetting the fact that Humanists (or any other non religious/poverty/education Charity) needs to benefit ALL of society. A Religious “Charity” need only benefit themselves….
Could you please tell me why advancing religion should be of benefit ONLY to themselves rather than the public/society as a whole?
🙂
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Haha. I’ve been trying that but got accused of trying to avoid something.
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You are kinda special aren’t you Moj…like Ian maybe….?
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You are currently free to make donations before tax.
Thank you, I’m aware of that and I repeat unaltered my previous comment , including its concluding question.
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(aside, btw Christopher, well done on the action and result in regard to anti fluoridation advertising, I forgot to say so in an earlier thread)
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Thanks Richard 🙂
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Richard
Have I misunderstood your position? Perhaps you could rephrase it.
And this statement is false if the income from commercial activity is donated.
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And this statement is false if the income from commercial activity is donated.
Is trade not a commercial activity?
Commercial activity is not defined by where the proceeds wind up but by the nature of the activity. In the case of Sanitarium Food the activity is trade.
The Sanitarium Health & Wellbeing Company is the trading name of two sister food companies (Australian Health and Nutrition Association Ltd[1] and New Zealand Health Association Ltd).
(My emphasis)
http://en.wikipedia.org/wiki/Sanitarium_Health_and_Wellbeing_Company
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Actually MoJ, your argument, as well as being disingenuous, highlights the dishonesty of the religious organisations calling their commercial operation charity and calling a commercial transaction an act of donation. I’m 100% positive that most purchasers of Sanitarium’s products, for example, don’t consider the transaction a donation.
Now, how about answering my earlier question and Ken’s question as to if you have any interest in any religious charity or other charity.
Here is my question for the third time:
Nor in my view is promoting religion, the supernatural or make-believe a charitable activity. What is your view on this?
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It gets worse, according to Wikipedia Sanitarium has revenue of A$300 million in untaxed income (presumably p/a?).
yet according to http://www.sanitarium.co.nz/community/community-support-and-sponsorship
it appears they limit their support :
You have to wonder where the cash ends up.
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How ’bout this moj,
sanitarium could give away all of its profits to a “real” charity so that all of society could benefit?
…. What I hear you say?…there is more chance of a camel passing through an eye of a needle?
(Sigh)
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The wriggle. The squirm.
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Christopher
If Sanitarium were required by law to give its profits to “real” charities would that satisfy all of your objections to its existence and charity status?
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Ah finally moj, they are privileged. Now that wasn’t so hard now was it?
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If Sanitarium were required by law to give its profits to “real” charities would that satisfy all of your objections to its existence and charity status?
It would be a start.
Better than giving away Weetbix.
I’d like to go further and re-examine the whole rationale of allowing the promotion of religion as reason to qualify an organisation (or even an individual) as a charitable entity. A point that MoJ is loudly silent on.
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I know what I wrote but I have no idea what you read. 🙂
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‘I know what I wrote but I have no idea…’
I know exactly what you mean 🙂
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