My client is a self-employed electrician. He travelled from home to 10 various assignments in 4 years, but one job lasted 14 months. HMRC has agreed that he is an itinerant worker, but has disallowed his travelling costs for 2014 on the grounds that he performed one job only in that tax year, quoting Horton v Young & BIM 37675.
I've studied the judgement in Horton v Young & nowhere does the judge refer to a time limit on a particular job. HMRC appear to have made the assumption in BIM 37675 that there must be at least 2 jobs in a year, but this leads to the bizarre situation of my client travelling to the job in question on April 5 2013 & his costs are allowable, but from 6 April 2013 to 5 April 2014 they are not allowable. This flies in the face of natural justice & any thoughts welcome please.