SE21811 - Benefits: special security measures: conditions to be satisfied

Section 50 Finance Act 1989

A nominated Inspector should deal with all claims relating to security expenditure ( SE21816).

All the following conditions are to be satisfied before a deduction under Section 50 Finance Act 1989 may be given.

• The security asset or service is provided for or used by the employee to meet a special threat to his personal physical security.
• That threat arises wholly or mainly by virtue of the particular employment he holds.
• The person providing the security measures (or reimbursing their cost) has the meeting of that threat as his sole object. (This ensures that any intention on the employer's part to reward his employee by meeting security expenditure will disqualify it.)
• In the case of a security service, the benefit to the employee consists wholly or mainly of an improvement of his personal physical security.
• In the case of a security asset, the provider intends it to be used solely to improve the employee's personal physical security. (But see SE21814 below where the provider intends the asset to be used only partly for that purpose.)

These conditions are tightly drawn. The deduction is intended for people whose work 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.