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HMRC internal manual

Employment Income Manual

HM Revenue & Customs
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Travel expenses: travel for necessary attendance: definitions: temporary workplace: example

A computer consultant is the only employee of a company that she controls. She is a specialist in banking systems. She spends 18 months working full-time at the headquarters of a merchant bank in Lombard Street in the City of London. She then moves next door to design a new computer system for a different bank where she expects to stay working full-time for 22 months. After that assignment she moves to a bank close by on Cheapside for 17 months. The employee expects to work continuously in the City of London albeit on the premises of different banks. Her travel from home to work will be broadly the same every day. No deduction is due for the cost of travel between her home and any of these workplaces.

This example illustrates the effect of the rule in Section 339(7) ITEPA 2003 that requires us to ignore a change of workplace if that change does not have any significant effect on the employee’s journey to work, see EIM32280.

Each of these workplaces would be capable of being a temporary workplace because her attendance is for a limited duration, see EIM32075. Each workplace taken in isolation would not be excluded from being a temporary workplace by the further rule explained in EIM32080. Her attendance is in the course of a period of continuous work (she works at each workplace for 40% or more of her working time) but her time at each workplace taken in isolation does not exceed 24 months. However, when we ignore the change of workplace and consider the length of time spent at the three workplaces as if they were a single workplace, the total time spent does exceed 24 months. Therefore each of these workplaces is a permanent workplace.