A proportion of accommodation expenditure for a trainee maxillofacial surgeon was wholly, exclusively and necessarily for the purpose of employment by reference to the amount of time spent giving advice from the accommodation while on-call.

At the beginning of 2012, the appellant was a qualified dental surgeon with 17 years’ experience and practised dental surgery in Southampton where he lived with family. The appellant wished to become a maxillofacial surgeon, but the only available position was in South London.

As the appellant’s family was established in Southampton and his period of training was from October 2012 to October 2016, in the first week he