Michael v Revenue and Customs (Income tax - Expenses incurred in the performance of duties of employment) [2026] UKFTT 96 (TC) (09 January 2026)

Michael v Revenue and Customs (Income tax - Expenses incurred in the performance of duties of employment) [2026] UKFTT 96 (TC) (09 January 2026)

Southport hospital was the appellant's permanent workplace as he attended there for all or almost all of the relevant periods of work, making travel expenses ordinary commuting and not deductible. Non-travel expenses did not meet the statutory requirements for deductibility under section 336 ITEPA, except for those already allowed by HMRC.

Citation
[2026] UKFTT 96
Parties
Appellant: Victor Michael; Respondents: The Commissioners for Her Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
09 January 2026
Procedural Posture
Tax Appeal / First Tier Tribunal Judgment
Outcome
Appeal dismissed
Legal Topics
Income Tax, Employment Expenses, Travel Expenses, Deductibility of Expenses
Tax Law Income Tax Employment Expenses Travel Expenses Deductibility of Expenses

Case Brief

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Parties

Victor Michael

Appellant

The Commissioners for Her Majesty's Revenue and Customs

Respondents

Procedural Posture

Tax Appeal / First Tier Tribunal Judgment

Legal Issues

  1. 1 Whether travel and other employment expenses claimed by the appellant are deductible under the Income Tax (Earnings and Pensions) Act 2003 (ITEPA)
  2. 2 Whether Southport hospital was a permanent or temporary workplace for the purposes of ITEPA
  3. 3 Whether non-travel expenses were incurred wholly, exclusively and necessarily in the performance of employment duties

Ratio Decidendi

Southport hospital was the appellant's permanent workplace as he attended there for all or almost all of the relevant periods of work, making travel expenses ordinary commuting and not deductible. Non-travel expenses did not meet the statutory requirements for deductibility under section 336 ITEPA, except for those already allowed by HMRC.

Court Disposition

Appeal dismissed