Duality of Purpose

    October 2013

    The Case of Healy Provides a New Angle On This Principle

    The Upper Tribunal has recently considered HMRC’s appeal in the case of Healy v HMRC [2013] UKUT 0337, where the First-tier Tribunal allowed Mr Healy a deduction from his professional income as an actor for the costs of renting a flat close to the theatre where he was in a long running production. The problem can be expressed comparatively simply. If he had stayed in a hotel close to the theatre, the expenditure would have been deductible, so why should the (no doubt cheaper) cost of renting a flat for exactly the same purpose not be tax-deductible?

     

    This article was first published in Tax Journal, 18 October 2013