BIM47305 - Specific deductions: security expenditure: conditions

All the following conditions are to be satisfied before a deduction may be given under FA89/S112:

  • the security service or asset is provided or used to meet a special threat to the individual's personal physical security,
  • that threat arises wholly or mainly by virtue of the particular trade carried on,
  • the sole object of the person incurring the expenditure is the meeting of that threat,
  • in the case of a security service the benefit resulting to the individual is wholly or mainly an improvement of his personal physical security,
  • in the case of a security asset the person incurring the expenditure intends the asset to be used solely to improve personal physical security,

The conditions are intentionally tightly drawn and are intended for people whose work or trade exposes them to a very real threat to their physical safety from terrorists, extremists and others who may resort to violence. It follows that a deduction cannot be given for:

  • security measures against the kind of general criminal threat which all citizens may face to a greater or lesser degree, for example when travelling home late from work; or
  • expenditure incurred primarily to meet a threat to property (including cash and other personal belongings); or
  • security measures taken against a threat unconnected with a person's employment or trade.

Cases in which there is doubt or dispute over whether there is a threat to physical security should be referred to CT&VAT (Technical).