The taxpayer’s travel and attributable expenses to a hospital where he worked were ordinary commuting expenses and so were not deductible for tax purposes as the hospital was his permanent workplace, and non-travel expenses were not deductible expenses, save for certain expenses allowed by HMRC. 

The appellant undertook work for NHS Professionals and claimed business travel, subsistence and other expenses in his tax returns for 2021/22 and 2022/23. The journeys for 2021/22 were to Southport hospital, a return journey of 94 miles from the appellant’s home in Manchester. The journey was the same for each of 227 days. For 2022/23, the appellant stated that the same return journey from his home to Southport hospital was undertaken for 77 days. HM Revenue and