Losses arising from theft or misappropriation by an employee are
normally allowable. For this purpose you should not regard a
director as an employee; also the proprietor of the business (sole
trader or partner) is not an employee. So losses arising from
theft/misappropriation by directors or business proprietors are not
allowable. (See Curtis v J & G Oldfield Ltd [1925] 9TC319 (see
BIM37810) and Bamford v ATA Advertising
Ltd [1972] 48TC359.)
For guidance on the meaning of director see EIM20200
onwards.
