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The lessons that tax advisers can learn from the Tim Healy case on the “wholly and exclusively” test for business expenses
KEY POINTS
- The decision in the Tim Healy case confirms the duality of purpose principle.
- The original decision of the First-tier Tribunal found no duality; the accommodation expenses were incurred for his acting business.
- Local subsistence and travel costs were not allowable.
- The Upper Tribunal set out various principles that were relevant.
- When incurring an expense the conscious and unconscious motives of the taxpayer must be taken into account.
The First-tier Tribunal recently released its revised decision in the case of the actor Tim Healy. It remains to be seen whether there will be a further appeal but it is another blow for taxpayers in their ongoing...
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