In the case of Healy, an actor who rented a flat close to a theatre where he was performing in a long-running production, sought a tax deduction for his rental costs. Peter Vaines considers the decision of the Upper Tribunal and whether the duality of purpose test actually applies.
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...
