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A recent case highlights aspects of the expenses rules for employment income. MIKE SCOLTOCK explains its impact
KEY POINTS
- Restating the general expenses rule
- The bases of the expenses claims
- A review of the Ansell v Brown case
- An analysis of the Emms case
- What does 'in the performance of' mean?
- The duality principle
Professional rugby whether union or league does not commonly feature in Taxation but a recent Special Commissioners case Emms v Revenue and Customs Commissioners SpC 668 has re-highlighted the contentiousness around the strictness with which ITEPA 2003 s 336 (previously TA 1988 s 198) is applied.
The reader is referred to two excellent previous articles on the deductibility of the expenses of professional rugby union players: Failing to convert the taxman and A try for a revenue conversion both by Mike Down and David...
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