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HMRC internal manual

Employment Income Manual

HM Revenue & Customs
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Tax treatment of teachers, lecturers and tutors: school teachers' expenses: travelling expenses: supply teachers

Sections 337 and 338 ITEPA 2003

A supply teacher is not attached permanently to a particular school but performs relief duties at any school to which he or she is directed by the employer. The length of the spell of duty at a particular school varies between half a day and a school term (or longer).

The school at which the teacher is for the time being working is generally regarded as his or her permanent workplace (see EIM32065 and EIM32125 onwards for agency workers) so that payments made to the teacher for the cost of travel between home and that school are earnings, see EIM10070, and are subject to PAYE.

Expenses incurred by the teacher in travelling to and from the school are not deductible under Section 338 ITEPA 2003 if the school is a permanent workplace because they are expenses of ordinary commuting, see EIM32055.

The decision of the Special Commissioner in Warner v Prior (SpC353) supports this conclusion and confirms that travel between home and school is not travel in the performance of the duties of the employment for the purpose of Section 337 ITEPA 2003, see EIM32356.