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S Long v HMRC

In S Long v HMRC (TC01843 – 9 March) an American citizen (L) took up employment with Goldman Sachs in London in 2004. He rented a house in the UK and claimed deductions for the rent the costs of travel from the house to his office and for ‘subsistence expenses’.

HMRC rejected the claim and L appealed contending that since he had intended to return to the USA within two or three years his office in London should be treated as a ‘temporary workplace’ for the purposes of ITEPA 2003 s 339. The First-tier Tribunal rejected this contention and dismissed L’s appeal.

Judge Radford held that the London office ‘did not qualify as a temporary workplace and therefore the travel and subsistence expenses were not deductible’.

Why it matters: ITEPA 2003 s 339 defines a ‘temporary workplace’ as ‘a place...

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