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HMRC internal manual

Business Income Manual

Specific deductions: administration: overseas conferences

Expenditure incurred in attending overseas conferences and study tours is allowable only when incurred wholly and exclusively for the purposes of the trade of the trader claiming the expense as a deduction. Thus, if there is a recreational element, evidence of which is often apparent from the fact that the trader is accompanied by a spouse, civil partner or a close relative, there is an argument that the whole cost is disallowable (Bowden v Russell and Russell [1965] 42TC301 (see BIM37610). Again, if the trader is attending in a representative capacity, the purpose of the expenditure is not exclusively for his trade (see the comments of Cross J on page 439 in Edwards v Warmsley, Henshall and Co. [1967] 44TC431 - see BIM37615). You should normally inspect the itinerary or programme; the total time taken in relation to the time spent in conference, as well as the type of tourist attractions visited, may be indicative of duality of purpose.

In the case of attending an overseas conference and where there is a clearly identifiable business element (and cost) you may allow the identifiable business element of the expenditure on the grounds that that part is exclusively for business purposes - see BIM42115. The costs of travelling to and from such a conference would not be allowable, no identifiable part of the travel costs is wholly and exclusively for the purpose of the trade.

Where the trader is a company, you should assess the director or employee whose expenses were reimbursed (see EIM31950). In that event you should allow the expense in full to the company as a form of additional cost of employment.