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HMRC internal manual

Employment Income Manual

Travel expenses: travel for necessary attendance: the 24 month rule: how to find out the expected period of time at a workplace: example

A project manager for a French company is seconded to oversee a project in the UK. The project is expected to last 3 years. He has an initial secondment for 6 months but it is expected that his secondment will be extended for the duration of the project as long as his work is satisfactory. He has been assured that there is no reason to suppose that his secondment will not be extended.

On these facts it is reasonable to assume that he will be in the UK at the project site for the full 3 years of the project. As his secondment can be expected to last for morethan 24 months the UK project site will not be a temporary workplace, see EIM32080. No deduction can be permitted under Section 338 ITEPA2003 for his travel costs or for his accommodation and subsistence costs while in the UK, see EIM32100. Section 373 ITEPA 2003 provides for relief for any payments made or reimbursed by the employer for certain travel between France and the UK, see EIM35010.