Most employees get no income tax relief for courses, exams or qualifications they pay for themselves, even when the training is closely linked to their job. Section 336 ITEPA 2003 only allows costs incurred in actually performing the duties of the employment, and HMRC and the courts treat training as preparation for the work rather than doing it. Relief is available in narrow cases, mainly where the employee is on a genuine training contract and the training is itself one of the contractual duties.
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Why does an employee usually get no relief for a course they fund?
An employee’s expenses are deductible from employment income only if they pass every test in section 336 ITEPA 2003. HMRC’s Employment Income Manual at EIM31630 lists them: each holder of the job would have to incur the expense, it must be necessarily incurred, it must be incurred in the performance of the duties, it must actually be incurred and paid, and it must be wholly and exclusively for that purpose.
Training nearly always fails the third test. EIM31650 explains that the expense must be incurred in actually carrying out the duties of the job. It is not enough that the cost is relevant to the job, that it puts the employee in a position to start work or that it keeps them qualified to do the work. Costs of preparing or training to carry out the duties are not deductible.
EIM32525 applies this directly to education: no deduction should normally be given for external education paid for by an employee, even where the subject is closely relevant to the job. The leading case, Blackwell v Mills, concerned a laboratory assistant who had to attend classes as a condition of his employment and was refused relief for travel to the classes and for textbooks. In Humbles v Brooks, a headmaster who attended weekend lectures to improve his knowledge of a subject he taught was also refused relief (EIM32530).
Does it help if the training is compulsory?
Usually not. HMRC’s view at EIM32530 is that continuing professional education is not deductible, even where participation is compulsory and failure could cost the employee their professional qualification or their job. CPE is not treated as a duty of the employment for section 336. The Special Commissioners took that line in Consultant Psychiatrist v CIR (SpC557), and a doctor attending seminars was refused relief in Parikh v Sleeman.
Examination fees are treated the same way. EIM32520 says fees paid to sit professional and other examinations are not deductible because they may improve the employee’s ability to do the job but are not incurred in performing it. In Lupton v Potts an articled clerk could not deduct the fee for the Law Society exams, and in CRC v Decadt a hospital doctor was refused relief for travelling to and sitting external professional examinations.
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When can an employee get relief for training costs?
The main exception comes from HMRC v Dr Piu Banerjee [2010] EWCA Civ 843. The Court of Appeal accepted that training costs should be deductible where the employee is employed on a training contract, training is an intrinsic contractual duty of the job, any personal benefit is incidental and the other conditions of section 336 are met (EIM32535).
HMRC expects the employee to be able to show, from the employment contract and other documents, that:
- training is an intrinsic part of the contractual duties of the employment
- all other duties are undertaken as part of the training process, as the practical side of it
- external training is a mandatory requirement of the job, although being mandatory is not enough on its own
- failing to complete the training and obtain the qualification means the employee cannot continue in the role that would otherwise have been available after qualifying
HMRC publishes a list at EIM32540 of medical courses and exams where it accepts that relief is due, such as MRCP Part 1, the MRCGP Applied Knowledge Test and the Primary FRCA written exam. EIM32545 confirms that training in other professions can qualify if the same strict conditions are met.
A second, narrower case is research. EIM32545 gives the example of a university scientist who must attend presentations by others in her field as part of the research programme she is employed to carry out. Attending is part of the research itself, so the cost is deductible.
What about trainees who pay for their own resits?
This is where many claims fail. EIM32545 gives the example of a trainee accountant employed to keep the company’s books who is contractually required to pass exams and pays privately to resit those he failed. His duties include bookkeeping, so he is not on a training contract where training is the intrinsic duty. The resit costs are not incurred in performing the duties and are not deductible. The contrasting example is a registrar on a training contract who must attend external courses to keep a national training number; travel, course fees and associated costs are allowed.
Are there better routes than claiming relief yourself?
Often, yes. If the employer pays for the training or reimburses the employee, section 250 ITEPA 2003 removes any tax charge on work related training, whether the employer pays the provider directly or repays the employee (EIM01210). The definition is wide: it covers training likely to be useful in the current job or one that will qualify the employee for it (EIM01220), and training for a related job with the same employer that the employee has a serious opportunity of holding (EIM01230). EIM01210 is clear, though, that section 250 gives no relief where the employee bears the cost and is not reimbursed. Our guide to the employer funded training exemption covers the detail.
Other routes worth checking:
- Payments by an employer to an employee attending a full time course at a university or college can be exempt under Statement of Practice 4/86. The employee must be enrolled for at least one academic year and attend for at least 20 weeks in that year, and for courses starting on or after 1 September 2007 the payments, excluding tuition fees, must not exceed £15,480 for the academic year (EIM06220). See scholarships and bursaries.
- Annual subscriptions to approved professional bodies are relieved under separate rules. GOV.UK confirms relief for professional membership fees you must pay to do your job and for subscriptions to approved bodies relevant to your job. See professional subscriptions and List 3.
- Employees who are leaving may have retraining paid tax free under separate rules, covered in outplacement and retraining for leaving employees.
How is a valid claim made?
GOV.UK explains that you must have paid tax in the year you claim for, and the relief cannot exceed the tax you paid. Relief is given at your rate of tax, so a £60 claim by a basic rate taxpayer is worth £12. A claim for the current year is usually given through your tax code, and an earlier year by a code change or refund. If you file a Self Assessment return, you must claim through the return. The general route for employees is explained in our guide to claiming employment expenses.
Keep the evidence. For a training contract claim, EIM32535 stresses the employment contract and supporting documents, so keep the contract, the training programme requirements and receipts.
How does this work in practice?
Illustration only. Two employees each pay £500 of their own money for an exam and pay income tax at 20%.
| Employee | Position | Relief |
|---|---|---|
| Specialty trainee doctor on a training contract, sitting an exam on HMRC’s list | Training is an intrinsic contractual duty | £500 deduction, worth £100 |
| Trainee accountant employed as a bookkeeper, paying for a resit | Training is preparation for the job, not a duty of it | Nil |
If the accountant’s employer had reimbursed the £500, section 250 would normally have made the reimbursement tax free, which is why asking the employer to pay is usually the better route.
What mistakes come up most often?
- Claiming CPE, conferences or courses because the employer or professional body requires them. Compulsion does not make the cost deductible (EIM32530).
- Claiming costs the employer has repaid. GOV.UK says you cannot claim if your employer gives you all the money back, and where only part is repaid you can claim only the part that was not.
- Assuming every doctor or trainee qualifies. The Banerjee exception depends on a training contract; a hospital doctor who was not employed on one was refused relief in Decadt (EIM32535).
- Applying the business rules. Self employed people and companies use the wholly and exclusively test for trading income, which is different; see whether training costs are tax deductible for a business.
- Estimating a claim and not correcting it. GOV.UK says that if your actual spending differs from an estimate you must tell HMRC and send evidence.
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Related Accountapedia entries
- Employer funded training: the tax exemption
- Can an employer pay into an employee’s ISA
- Is a company director an employee
- Worker, employee or self employed: employment rights
- AML training requirements for practice staff
Related cover: Employers liability insurance: the legal requirements and Employers liability vs public liability.
Sources
- GOV.UK: Manual page EIM31630
- GOV.UK: Manual page EIM31650
- GOV.UK: Manual page EIM32525
- GOV.UK: Manual page EIM32530
- GOV.UK: Manual page EIM32520
- GOV.UK: Manual page EIM32535
- GOV.UK: Manual page EIM32540
- GOV.UK: Manual page EIM32545
- GOV.UK: Manual page EIM01210
- GOV.UK: Manual page EIM01220
Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 24 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.
