B2.471 Security expenses

B2.471 Security expenses

The 'wholly and exclusively' rule (see B2.315) means that expenditure on special personal security measures which benefits an individual personally (and not merely the individual's trade) is not normally deductible. However, a deduction is available for the expense if the following can be shown¹:

1.  

   •     an individual is carrying on a trade (either alone or in a partnership of other individuals)

2.  

   •     there is a special threat to the individual's personal physical security which arises wholly or mainly because of the trade

3.  

   •     there is a service or asset which improves personal security which is used by the individual or provided for the trader to meet the threat

4.  

   •     in the case of a service, the benefit to the individual of the