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Moving on
Key points
- Defining a temporary workplace.
- The 24-month threshold for a temporary workplace.
- Is there a defined area within which work is performed?
- Modifying the workplace and its effect on the journey.
- Did HMRC contradict its manuals in the Sambhi case?
- Given the size of construction projects and delays during the pandemic is the 24-month limit outdated?
The case of Narinder Sambhi (TC7717) was reported in Taxation 15 October 2020 page 22 and is worthy of more detailed examination as to the light it sheds on the deductibility of travel expenses. But before delving further into that case it is worth exploring the legislation in ITEPA 2003 s 339: ‘Meaning of “workplace” and “permanent workplace”’. And in doing so it may help to consider the example of Harry a leading expert in his field who is employed by a firm of tax...
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