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 it was attended for all or almost all of the relevant periods, making travel expenses ordinary commuting and not deductible. Non-travel expenses did not meet the statutory requirements for deductibility under section 336 ITEPA.

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

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Parties

Victor Michael

Appellant

The Commissioners for Her Majesty's Revenue and Customs

Respondents

Procedural Posture

Income Tax Appeal / First Tier Tribunal (tax Chamber) Judgment

Legal Issues

  1. 1 Whether travel and other expenses claimed by the appellant are deductible under ITEPA 2003
  2. 2 Whether Southport hospital was a permanent or temporary workplace for the appellant
  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 it was attended for all or almost all of the relevant periods, making travel expenses ordinary commuting and not deductible. Non-travel expenses did not meet the statutory requirements for deductibility under section 336 ITEPA.

Court Disposition

Appeal dismissed