In Dr Samad Samadian v HMRC (FTC/53/2013 – 15 January 2014) the issue was the deductibility of travel expenses incurred by a consultant geriatrician.
Dr Samadian worked in full time employment at two NHS hospitals and maintained a private practice as a self-employed medical practitioner – for which he maintained an office at home and rented consulting rooms at private hospitals.
The appeal concerned the deductibility of expenses on travels between the NHS hospitals and the private hospitals between home and the private hospitals and between the NHS hospitals and patients’ homes for home visits.
Under ITTOIA 2005 s 34 those expenses could only be deductible if they were incurred ‘wholly and exclusively’ for the purpose of Dr Samadian’s profession.
The tribunal accepted that the taxpayer’s home office was a place of business and so travels between his home and other places of business could be deductible...
