For an employee or director to be allowed a particular deduction, the following conditions must be satisfied:

the employee, etc. must be obliged to incur and pay the expense as holder of the employment; and

the expense must be wholly, exclusively and necessarily incurred in the performance of those duties (see ¶9153).

‘Wholly and exclusively’

Wholly and exclusively means that there cannot be any dual purpose in incurring the expenditure. Thus, expenditure which is partly incurred for personal purposes (e.g. on food or clothing) will normally be disallowed. However, HMRC may sometimes allow a proportionate part of the expenditure. See further ¶9189 and ¶5810.

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