SE70755 - Tax treatment of teachers, lecturers and tutors: school teachers' expenses - travelling expenses - supply teachers

A supply teacher is not attached permanently to a particular school but performs relief duties at any school to which he or she is directed by the employer. The length of the spell of duty at a particular school varies between half a day and a school term (or longer).
The school at which the teacher is for the time being working is generally regarded as his or her permanent workplace (see SE32065 and SE32125 onwards for agency workers) so that payments made to the teacher for the cost of travel between home and that school are emoluments chargeable under Section 19(1)1 ICTA 1988, see SE10070, and are subject to PAYE.

Expenses incurred by the teacher in travelling to and from the school are not deductible under Section 198(1) ICTA 1988 if the school is a permanent workplace because they are expenses of ordinary commuting, see SE32055.

The decision of the Special Commissioner in Warner v Prior (SpC353) supports this conclusion and confirms that travel between home and school is not travel in the performance of the duties of the employment for the purpose of Section 337 ITEPA 2003, see SE32356.