SE35004 - Travelling expenses - employees working but not domiciled in the United Kingdom - use of employees' own vehicles from 2002/03 onwards

Section 197AD and 197AF and Schedule 12AA ICTA 1988 as introduced by Section 57 and Schedule 12 FA 2001

Non domiciled employees who work in the UK may use their own vehicles for business travel. Approved mileage allowance payments (AMAPs) paid to employees in respect of business travel in their own vehicles are exempt from tax from 2002/03. The actual cost of such travel is no longer deductible under Section 198(1) ICTA 1988 after 5 April 2002. However, employees may be entitled to a deduction for mileage allowance relief (MAR) for travel that would have qualified for tax relief under the Section 198 rules (see SE31800 onwards). This may be the case whether or not they receive AMAPs. See SE31205 for an overview of the new system.

Where a deduction is not due under the general rule in Section 198(1), non domiciled employees may still obtain relief under the special rules in Section 195 ( SE35002)

Section 195 provides for a deduction for the cost of an employee's journeys between the country where the employee normally lives and the UK. SE35050 sets out the conditions that have to be satisfied. The definition of "business travel" in the AMAPs and MAR legislation also applies to journeys covered by Section 195. The effect of this is that where MAR is available in respect of the use of a vehicle -

  • no deduction may be made under Section 195 but
  • the travel will be eligible for MAR if, in the absence of MAR, a deduction would have been available for it.

It follows that AMAPs will be exempt and MAR may be due for employees who use their own vehicles for travelling between the country where they normally live and the UK provided that all the other conditions for relief under Section 195 have been satisfied.

Section 195 also provides relief for the travelling expenses of an employee's family where certain conditions are satisfied ( SE35050). The legislation providing for the exemption for AMAPs and for MAR requires an employee to use a qualifying vehicle for business travel. Therefore, the exemption for AMAPs and MAR may be available when the family accompanies the employee but not when the family travels alone. The additional exemption for passenger payments is unlikely to be available for family members who accompany the employee. This is because qualifying passengers have also to be employees for whom the travel is business travel - Section 197AE(2).