A non-profit organisation whose principal purposes are beneficial to the community may be denied charitable status if its activities are so controlled by government, or so closely associated with the implementation of government policy, that it should be properly characterised as carrying out the work or function of government. The primary factors include: degree of government control over board appointments, whether created under the aegis of government, extent of government funding and control of expenditure, extent to which government prescribes performance standards, and whether government has assumed responsibility for the services. Mere economic dependence on government funding is not alone determinative, but outcomes-based funding agreements that specify objectives and require reporting may establish sufficient control. The question was left open whether the government function analysis for public benevolent institutions is identical to that for charities.
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