Before I argue that its not tax deductible, can anyone point me in the direction of relevant legislation to back up the poistion thats its not tax deductible, or to show me I might be wrong.
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You could show him BIM45560.
I'm not aware of any specific legislation, but I would imagine that it simply fails on the "wholly and exclusively" principle
I generally hate quoting HMRC "guidance" to clients but in this case I agree with the above that sending the client a link to BIM45560 is the quickest way to curtail any arguments from the smart-[***] clients out there.
https://www.gov.uk/hmrc-internal-manuals/business-income-manual/bim45560
I wouldn't disagree with sending the link, but if he's a real smart-[***] client he'll point out that PHI and PMI are two different things (not that it changes the tax analysis in any way).
Shouldn't you be asking the client for the legal references if they profess to be that much of an expert?
Maybe it's locum insurance. https://www.gov.uk/hmrc-internal-manuals/business-income-manual/bim45565