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The taxpayer an author and journalist lived in London and owned a boat normally moored on the Thames. He used it when taking photographs and obtaining material for a book about the river.
In early 2006 he decided to do further research but this time in France. The boat was moved to Port Grimaud where it was moored for some time. The taxpayer and his wife lived on the boat while it was there.
He claimed £10 000 against his income as ‘expenditure... for moving mooring and living on the boat in the south of France’.
HMRC disallowed the claim on the basis that under ITTOIA 2005 s 34 the expenditure was not incurred ‘wholly and exclusively for the purposes of the trade’. That is ...
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