Accommodation and travel expenses from Scotland to Swindon to be closer to work were not wholly and exclusively incurred for the purposes of the taxpayer’s trade.
The appellant was engaged as a self-employed subcontractor by a large engineering company. On 6 April 2018, HM Revenue and Customs (HMRC) opened an enquiry into the appellant’s self-assessment return for the tax year ended 5 April 2017.
A dispute arose concerning the tax treatment of the accommodation and travel expenses he claimed between his home in Melrose, Scotland and a hotel in Swindon, where he lodged while working in the tax year in question. The appellant maintained that the expenses claimed were wholly and exclusively incurred in his self-employment. HMRC disagreed. Correspondence and further enquiries followed before HMRC issued a closure notice assessing additional tax 
