Nwaneri v Revenue and Customs (Income tax - Expenses incurred in the performance of duties of employment - Travel expenses - Subsistence expenses - Whether deductible - Penalties - Whether behaviour deliberate) [2026] UKFTT 581 (TC) (15 April 2026)

Nwaneri v Revenue and Customs (Income tax - Expenses incurred in the performance of duties of employment - Travel expenses - Subsistence expenses - Whether deductible - Penalties - Whether behaviour deliberate) [2026] UKFTT 581 (TC) (15 April 2026)

The appellant's workplaces were permanent, so travel and subsistence expenses were ordinary commuting and not deductible. The appellant knowingly included inaccurate and excessive expenses in his returns, constituting deliberate behaviour. Penalties were correctly imposed for deliberate inaccuracies.

Citation
[2026] UKFTT 581
Parties
Appellant: Mr Nwaneri; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
15 April 2026
Procedural Posture
Tax Appeal / First Tier Tribunal Judgment
Outcome
Appeal dismissed
Legal Topics
Income Tax, Employment Expenses, Travel Expenses, Subsistence Expenses, Penalties for Deliberate Inaccuracies, Self Assessment Returns
Tax Law Employment Law Income Tax Employment Expenses Travel Expenses Subsistence Expenses Penalties for Deliberate Inaccuracies Self Assessment Returns

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 5 Authorities cited 10 Party arguments 2 Amounts and remedies 6
Sign in to unlock

Parties

Mr Nwaneri

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Tax Appeal / First Tier Tribunal Judgment

Legal Issues

  1. 1 Whether travel and subsistence expenses claimed by the appellant are deductible under ITEPA 2003
  2. 2 Whether the appellant's behaviour in submitting inaccurate returns was deliberate under Schedule 24 FA 2007
  3. 3 Whether the penalties imposed were correctly calculated and justified

Ratio Decidendi

The appellant's workplaces were permanent, so travel and subsistence expenses were ordinary commuting and not deductible. The appellant knowingly included inaccurate and excessive expenses in his returns, constituting deliberate behaviour. Penalties were correctly imposed for deliberate inaccuracies.

Court Disposition

Appeal dismissed

Orders

  • The appeal is dismissed in full.