Section 11(3) Post-Amendment, Accumulated Income and the Sixth Year: Legal Interpretation, Procedural Bounds and Administrative Implications

Prospectivity of tax amendments: changes to accumulation rules apply from their effective date, not to prior accruals.

Interpretation of section 11(3) concludes that, under the pre-amendment text, accumulated charitable funds could be applied in the year immediately following the five-year accumulation period; the 2022/2023 amendment removing that year was treated as prospective under the presumption against retrospective tax imposition. Separately, corrections by the Centralised Processing Centre under section 143(1) are confined to mechanistic errors and should not resolve debatable substantive questions of statutory interpretation.