Legislation: CAA 2001, s. 23 (List C, item 8, 11 and 12), 27, 33 and 63(5)

Cases: Cole Brothers Ltd v Phillips (HMIT) [1982] BTC 208; Carr (HMIT) v Sayer [1992] BTC 286; Bradley (HMIT) v London Electricity plc [1996] BTC 95; Lord Hanson v Mansworth (HMIT) (2004) Sp C 410; Brockhouse (t/a A5 Aquatics) [2011] TC 01235

HMRC material: CA21200, 22270; EIM21811


This heading is divided into two categories. The reason for this is that special rules apply to certain expenditure on personal security measures. Where these special rules do not provide tax relief, then the expenditure must be considered on general principles.

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