His write to relief

The appellant a self-employed journalist and author produced a rolling news programme on the internet relying on advertisers for his income. Consequently he claimed that it was essential for him to take his work with him wherever he was in the world.

As an author the appellant claimed relief on £10 000. This represented the expenses incurred for his book research around the south of France and included mooring his boat moving and living and thus he said was ‘wholly necessary’.

HMRC disagreed in regards to ITTOIA 2005 s 34 contending  that the conditions in that section had not been met and that the cost of general accommodation did not qualify as an expense incurred wholly and exclusively for business purposes.

The First-tier Tribunal found that the appellant’s expenses had...