BIM42525 - Specific deductions: administration: overseas conferences
Allow the identifiable business cost
Expenditure incurred in attending overseas conferences and study
tours is allowable only when incurred wholly and exclusively for
the purposes of the trade of the trader claiming the expense as a
deduction. Thus, if there is a recreational element, evidence of
which is often apparent from the fact that the trader is
accompanied by a spouse, civil partner or a close relative, there
is an argument that the whole cost is disallowable (Bowden v
Russell and Russell [1965] 42TC301 (see
BIM37610). Again, if the trader is
attending in a representative capacity, the purpose of the
expenditure is not exclusively for his trade (see the comments of
Cross J on p.439 in Edwards v Warmsley, Henshall and Co. [1967]
44TC431 - see
BIM37615). You should normally inspect
the itinerary or programme; the total time taken in relation to the
time spent in conference, as well as the type of tourist
attractions visited, may be indicative of duality of purpose.
In the case of attending an overseas conference and where
there is a clearly identifiable business element (and cost) you may
allow the identifiable business element of the expenditure on the
grounds that that part is exclusively for business purposes - see
BIM42130. The costs of travelling to and
from such a conference would not be allowable, no identifiable part
of the travel costs is wholly and exclusively for the purpose of
the trade.
Where the trader is a company, you should assess the director
or employee whose expenses were reimbursed (see EIM31950). In that
event you should allow the expense in full to the company as a form
of additional employment income.
