![]() Other expenses associated with general health and fitness were disallowed. The expenses were therefore only incurred for the purposes of his profession. Parsons v HMRC Commissioners TC 00421 where the costs of a knee operation, chiropractor and masseur expenses incurred by a stunt man were allowable because the expenditure had a ‘special character dictated by the occupation as a matter of physical necessity’ and any private purpose was an ‘unavoidable effect’ of the expenditure. ![]() Prince v Mapp 46 TC 169, where surgery costs to allow the taxpayer to play the guitar were disallowed (see BIM37945).Murgatroyd v Evans-Jackson 43 TC 581, where nursing home fees were disallowed because recovery from ill health was not a trade purpose (see BIM37950).Norman v Golder 26 TC 293, where it was concluded that doctor’s bills inevitably have a non-trade purpose (see BIM37940).The following cases should all be considered in connection with medical expenses: Medical expenses including physiotherapy, special diets and training expenses are typical examples where the purpose of the expenditure may include a non-trade element. Some expenses are likely however to cause difficulty where there is an intrinsic duality of purpose, see BIM37900 onwards. It is expected that in most cases it will be relatively clear whether or not an expense has been incurred wholly and exclusively for the purposes of the athlete’s trade. It does not cover every situation or expense. The guidance below is intended to explain the principles of the wholly and exclusively rule as applicable to professional athletes. Expenditure with an intrinsic duality of purpose However, where an identifiable part or proportion is incurred wholly and exclusively for the purposes of the athlete’s trade, that part is deductible. Where an expense is incurred for more than one purpose, the wholly and exclusively rule will usually prevent a deduction from being allowed. ![]()
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