The Courts have recognised that there may be exceptions to the
general rule in
EIM32455 that the cost of clothing is
The rules for computing taxable business profits contain a similar rule that expenses must be incurred wholly and exclusively for a business purpose. In the Trading Income case of Caillebotte v Quinn (50TC222) Templeman J commented that:
"the cost of protective clothing worn in the course of carrying on a trade will be deductible, because warmth and decency are incidental to the protection necessary to the carrying on of the trade.
In the same way a deduction can be permitted from earnings for the cost of protective clothing, see EIM32470. In the case of Hillyer v Leeke (51TC90) Goulding J recognised that the cost of clothing could be deductible where the clothing is:
"of a special character dictated by the occupation as a matter of physical necessity."
We also accept that specialist clothing can include clothing
that is a uniform or part of a uniform, see
A deduction can only be permitted where the employee must provide the specialist clothing at his or her own expense.