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HMRC internal manual

Business Income Manual

Specific deductions: security expenditure: overview

S81 Income Tax (Trading and Other Income) Act 2005

A deduction in computing the profits of a trade carried on by an individual (either alone or in a partnership of individuals) is allowed for expenditure of a revenue nature made with the intention of meeting a special security threat arising from the trade if:

  • the expenditure is incurred in connection with providing the trader with security assets or security services, or with the use of such assets or services (see BIM47310),


  • all the qualifying conditions are met (see BIM47305).

Relevant facts needed to establish that a deduction is due include the following.

  • Full details of the nature of the trade.
  • A description of the special threat to the individual’s security indicating how it arises and why it is considered to arise wholly or mainly because of the particular trade.
  • Details of the nature of the expenditure incurred on the security asset or on the security service, and, where it is not obvious, an explanation of how these are considered to improve the individual’s personal physical security. (Any other security arrangements in force such as police protection should be mentioned.)
  • Whether the expenditure on the asset or service is intended solely to improve personal physical security.
  • If the expenditure is only partly to improve personal physical security, the relative proportions of the security and non-security aspects.

If you obtain information about personal security arrangements, appropriate steps should be taken to keep that information secure and confidential.