Summary
A self-employed flying instructor was not entitled to a deduction for travel expenses from his place of business at home to two airports, which were also considered to be places of business. The expenses were not ‘wholly and exclusively’ for the purposes of his trade, profession or vocation.
Background
The taxpayer, a self-employed flying instructor and examiner, gave flying lessons and examined pilots invariably at two airports (i.e. Shoreham and Bournemouth). He operated the business from home, and travelled by car between his home (in Haywards Heath) and the airports. The taxpayer did not have an office or other accommodation at either airport or elsewhere. The taxpayer claimed the cost of travel between his home and the airports in his tax return for 2006/07.
HMRC decided that the taxpayer was not entitled to deduct his travel expenses
