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PE Edgar v HMRC

In PE Edgar v HMRC (TC01109 – 5 May) a pilot (E) claimed a deduction of more than £17 000 for the cost of training to qualify for his pilot’s licence. HMRC accepted that exam fees paid to the Civil Aviation Authority were deductible but rejected the majority of E’s claim.

The First-tier Tribunal dismissed E’s appeal. Judge Barton observed that the expenses had been incurred before E began his employment. Since he ‘was not in employment when these expenses were incurred he is not entitled to any deduction’.

Why it matters: ITEPA 2003 s 336 provides that a deduction for expenses is only allowable where the expenditure ‘is incurred wholly exclusively and necessarily in the performance of the duties of the employment’. The Tribunal upheld the established principle that preliminary expenditure incurred before an employment begins does...

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