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The call comes as an anonymous donor stepped in at the eleventh hour to offer £10m plus to help the National Gallery secure Joshua Reynolds’ portrait of Omai, regarded by some as the finest British portrait painted.

The issue of British institutions losing out on major works because of inadequate funding has been thrown into sharp relief because the multi-million pound campaign to keep the Omai portrait in the country came at the same time as the £29.5m bid for Raphael’s The Madonna of the Pinks, sold by the Duke of Northumberland to finance renovation works at Alnwick Castle.

Under the current rules, institutions are given a matter of months at most to come up with the cash to secure works before the government allows them to be exported. Few hold out much hope of another “white knight” donor coming forward for the Raphael in such a short space of time.

“Current fundraising campaigns highlight the almost insurmountable task faced by UK museums and galleries in their efforts to acquire them, not least when confronted with the superior purchasing power of overseas institutions and private collectors,” say the Art Fund.

“The problem can rarely be addressed through individual campaigns mounted to secure key masterpieces, and these often work in favour of the vendor rather than the nation and the taxpayer.”

The Export Reviewing Committee, who advise government ministers on whether certain works should be temporarily barred from export, have drawn public attention to the situation, pointing out that very few items valued in excess of £1m and subject to an export stop are ultimately saved for UK museums and galleries.

In other countries, such as France and Italy, the government can intervene and prevent works being exported, either through notification (where a simple export ban is introduced at the point of sale) or pre-emption (where the government acquires the work at the market price on behalf of a gallery or museum).

The Art Fund are not suggesting the UK government adopts these principles. The government is unlikely to budget for funding either acquisitions through pre-emption or the preemption process itself, and notification is likely to discourage owners from making works available as it tends to depress prices. But the Art Fund have come up with a three-point plan that they believe would improve the prospects of keeping important works in the country. The proposals, submitted to the Government last week, include measures to:

• Establish a system that would identify the most significant items at risk at the earliest
opportunity, thereby reducing the eleventh-hour rescue campaigns that are becoming all too familiar.

• Create a climate of private giving through greater tax incentives, including improvements to the present system and an extension of Gift Aid. The latter would allow donors to set gifts of works of art against tax bills, as is already possible with land and shares.

• Restore the annual government funding of the National Heritage Memorial Fund – the fund of last resort – to its pre-Lottery level of £12m, to give the system backbone and justify its existence.

The campaign ties in neatly with the Art Fund’s centenary conference, entitled Saving Art for the Nation, being held in association with The Art Newspaper on November 11 and 12.