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As described in E4.715A, an employee may not deduct the cost of ordinary commuting between home and a permanent workplace. It was felt that this rule was being nullified by certain structures involving employment intermediaries, where there is a single employment with multiple engagements at different workplaces, none of which could be classed as a permanent workplace in relation to the employment. From 2016/17, given certain conditions, each engagement must be treated as a separate employment for the purposes of the travel expenses rules, thus turning each workplace into a permanent workplace and denying relief for home to work travel expenses¹.

The rule that each engagement must be treated as a separate employment for travel expenses purposes potentially applies whenever a worker personally provides services other than excluded services (that is, services provided wholly in the client's home²) and the contract for those services is not directly between the worker and the client (or a person connected with the client) but involves an intermediary³. This initial proposition is very wide, and includes