Travel and subsistence costs of a locum nurse engaged by an agency were disallowed, as each placement was to be treated as a permanent workplace, and his training costs were disallowed as they were not wholly, exclusively and necessarily incurred.
The appellant was employed as a locum nurse for an NHS approved recruitment agency. Although the appellant’s agency assignments were always temporary, the location where the work was actually carried out was a permanent workplace for the duration of each engagement.
In November 2010, the appellant submitted self-assessment returns for the tax years 2007/08, 2008/09 and 2009/10, which included claims for travelling from his home to his various places of work, accommodation costs, subsistence, and training expenses. Following an enquiry into the appellant’s tax returns, HM Revenue and Customs (HMRC) disallowed the expenses claimed. The appellant appealed.
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