4

when TA 1988, section 380 allows the loss arising from an employment to be set off. The Notes to the Bill suggest that a loss can arise in three situations: (a) for ministers of religion, (b) where capital allowances exceed the earnings income and (c) where the loss arises because the employee’s contract makes him liable for losses as well as entitled to profits.

Section 330 forbids double deductions and section 331 provides an order in which deductions are to be made by referring to the relevant provisions elsewhere. For the rules where a foreign element is involved, see above at §13A.3.2.

18A.2    Chapter 2: Qualifying Travelling Expenses Paid by Employee8

  1. Section 337(1)(b) refers amounts necessarily incurred on travelling in the performance of the duties of the employment. The problem of two employments within one group is addressed by section 340 which provides expressly that expenses of travel by an employee between two places at which the employee performs duties of different offices or employments under or with companies in the same group, are treated as necessarily expended in the performance of the duties which the employee is to perform at the destination and so are deductible.9 A 51% subsidiary test is used to determine when companies are members of the same group.10
  2. Section 338 allows the expenses of travelling which (i) are attributable to the necessary attendance at any place of the holder of the office or employment in the performance of the duties of the office or employment, but (ii) which are not expenses of ordinary commuting or private travel.11 Of these, (i) is designed to clarify the law concerning the costs of travel to or from home or a temporary workplace, while (ii) is designed to prevent (i)

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