BIM47310 - Specific deductions: security expenditure: qualifying assets

A security asset or service is defined in FA89/S113 as an asset or service which improves personal security.

Qualifying assets

’Asset' includes equipment and a structure such as a wall. So, items such as alarm systems, bullet resistant windows, floodlighting, reinforced doors and windows and perimeter walls and fences will qualify. The right to a deduction is not affected by the fact that the asset may become affixed to land or a dwelling.

Rent paid to concerns specialising in the provision of alarm systems is allowable. Any installation charges which the trader is called upon by the agreement with the supplier to incur will normally be disallowable capital expenditure, although capital allowances may be available.

Non-qualifying assets

The following do not qualify as security assets:

  • cars, ships or aircraft,
  • living accommodation,
  • a dwelling,
  • grounds appurtenant to a dwelling.

What is a ’dwelling' is not defined. The word therefore has its normal meaning. In particular it includes a flat used as a residence, but a block of flats is not a single dwelling. A flat above business premises where the taxpayer lives (as in Mason v Tyson [1980] 53TC33) would also be a ’dwelling'.

What are ’grounds appurtenant to a dwelling' are also not defined, so take their normal meaning. Guidance on the normal meaning of the similar concept of ’garden or grounds' for the purposes of private residence relief from CGT is at CG64350 onwards.

Although living accommodation does not qualify as a security asset for the purposes of specific deductions under FA89/S112, this does not affect exemption from tax as earnings on living accommodation provided for employees as part of special security arrangements (ITEPA03/S100).

Security services

A security service includes such things as the provision of security guards or bodyguards.