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HMRC internal manual

Business Income Manual

HM Revenue & Customs
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Specific deductions: security expenditure: qualifying assets

S81 Income Tax (Trading and Other Income) Act 2005

The deduction for personal security expenses applies to expenditure incurred in connection with the use or provision of 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 fixed to land or that the trader may be or become entitled to the property in the asset (or, if the asset is a fixture, to any interest or estate in the land concerned).

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’.

The meaning of the expression ‘grounds appurtenant to a dwelling’ is also not defined, so takes its normal meaning. Guidance on the normal meaning of the similar concept of ‘garden or grounds’ for the purposes of private residence relief from Capital Gains Tax is at CG64350 onwards.


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