Doctor’s travel expenses

The taxpayer a specialist registrar was appointed to a six-year training programme in hospitals in Portsmouth Winchester Southampton and Bournemouth.

His base hospital throughout was in Winchester. As part of his remuneration package he was entitled to relocation expenses paid in respect of his travel from home to the place of rotational appointment. He claimed these in 2003/04 on the basis they exempt from tax.

In 2005/06 the registrar was paid call-out expenses while on rotation at Southampton. He claimed these were tax-exempt emergency call-out expenses on the basis that they met the conditions in HMRC’s Employment Income Manual para EIM10040; i.e.

• he gave advice about an emergency after receiving a telephone call;
• he took responsibility for the advice given; and
• he had continuing responsibility for the emergency while travelling to his normal place...