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HMRC internal manual

Employment Income Manual

Particular benefits: special security measures: part use of a security asset

Section 377 ITEPA 2003

A nominated Inspector should deal with all claims relating to security expenditure (see EIM21813).

Where the person providing the security asset intends it to be used only partly to improve personal physical security (Section 377(4) ITEPA 2003), the employee can only get a deduction for:

  • a proportion of its cost, or
  • a proportion of any reimbursed expenses in connection with its use.

The amount deductible is the proportion that is attributable to the provider’s intention that the asset be used to improve personal physical security.

If the provider intends the asset to be used solely to improve personal physical security, but there is another use for the asset which is incidental to that purpose, the employee is still entitled to a deduction of the whole of the cost or expenses (Section 377(3) and (4)). Thus, the cost of bullet resistant windows can be allowed in full although they have incidental non-security use in keeping out the cold.

Employee becomes the owner of the asset

If ownership of a security asset passes to the employee, this does not affect his right to a deduction provided all the qualifying conditions at EIM21810 are met. In particular this rule applies in the case of a fixture that is in a property that the employee owns.