There have been recent calls to modernise the law in Bermuda relating to charitable organisations and we expect to see a comprehensive review of the Bermudian non-profit sector in the near future. In determining what is charitable, Bermuda law historically looks to the 1601 Elizabethan Statute of Charitable Uses and the judgment of Lord Macnaghten in the 1891 case of the Income Tax Special Purposes Commissioners v Pemsel. The 1601 statute enumerates in its preamble the types of charitable trusts that were then in common use and provides in its body means for the protection and enforcement of such trusts. Following the Pemsel case and the 1601 statute, charitable purposes have principally been limited to (i) the relief of poverty; (ii) the advancement of education; (iii) the advancement of religion; and (iv) other purposes beneficial to the community not falling under (i), (ii) and (iii).