Samadian sets a very high bar for expenses incurred ‘wholly and exclusively’ for travel to or from a business based in the home.
As the First-tier Tribunal acknowledged in Samad Samadian v HMRC (TC02533) distinguishing the case from Horton v Young [1972] 1 Ch 1579 (the case of a self-employed bricklayer whose only office was at his home and whose expenses for travel to building sites were held to be allowable) the modern world is very different from that of the 1970s and there is now ‘an almost infinite variety of methods of working for the self-employed in the current era’.
Individuals who choose to conduct their business predominantly from their home address might previously have considered themselves entitled to deduct the cost of all business related travel from any self-employed...
