CA22270 - PMA: Buildings & structures: Personal security

CAA01/S33

PMAs are available if an individual, or a partnership of individuals, (but not a company) carrying on a trade, profession or vocation incurs expenditure in connection with the provision for, or use by, the individual, or any of the individuals, of a security asset and there is a special threat. They are also available where the individual or partnership carries on an ordinary property business, furnished holiday lettings business or overseas property business. Expenditure qualifies for PMAs under Section 33 if it does not already qualify for relief, either as a deduction or an allowance. The disposal value is nil.

A special threat is a threat to the individual's personal physical security that arises wholly or mainly because of the trade etc.

A security asset is an asset that improves personal security.

For this purpose asset includes:

• equipment,
• a structure (such as a wall), and
• an asset which becomes fixed to land.

Assets like alarm systems, bullet resistant windows, reinforced doors and windows, and perimeter walls and fences are the sort of assets that may qualify as security assets.

The following assets are not security assets:

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

Give dwelling its normal meaning. A flat used as a residence, including a flat above business premises, is a dwelling but a block of flats is not a single dwelling.

Follow the guidance at CG64362 onwards about what are the garden or grounds of a dwelling house for the purposes of the Capital Gains Tax private residence exemption if you have to decide what are grounds appurtenant to a dwelling.

Give PMAs on the whole of the expenditure where:

• there is another use for the asset which is incidental to the use for personal physical security, or
• the asset improves the personal physical security of a member of the individual's family or household, as well as the individual's own personal physical security.

Where a security asset is intended to be used partly to improve personal physical security and partly for other reasons, only an appropriate proportion of the expenditure on the asset is to qualify for an allowance. The appropriate proportion is that attributable to the intended use to improve physical security.