Two places of work

The taxpayer company was formed in 2002 to run hairdresser-training courses which took place mainly in schools colleges and salons.

The firm’s registered office was the home of the sole owners Mr and Mrs E; no training took place at the address. New premises were bought for the business in 2005 and a great deal of training was held there.

A car purchased in 2004 was kept at the registered office address and used solely for business; private use was not allowed. HMRC said the vehicle was available privately because Mr E drove it from his home to the office. He appealed saying his home address was his main place of work.

The First-tier Tribunal decided the main issue to consider was whether or not the registered address was where Mr E conducted his business.

The judge noted that ITEPA 2003 s 339 allows...