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For the tax treatment of double cab pickups from 6 April 2002 to 5 April 2025 please see EIM23150

From 6 April 2025, HMRC will no longer align its interpretation of the terms “carâ€� and “v²¹²Ôâ€� for tax purposes with the definitions used for VAT purposes.ÌýUnder the VAT approach double cab pickups are classified based on payload capacity, with anything under one tonneÌýclassified as a car, and anything a tonneÌýand over as a van. This rule was replicated as a pragmatic way of resolving the primary suitability and classification of double cab pickups.ÌýÌýÌý

This finely balancedÌýtest is at odds with the Court of Appeal ruling in Payne & Ors (Coca-Cola) v R & C CommrsÌý(2020) BTC19 (see EIM23121),Ìýwhich clarified the correct application of the “primary suitabilityâ€� test under Section 115 ITEPA 2003.ÌýThe ruling establishedÌýthat decisions should not be based on a narrow margin and that cases where no clear predominant suitability for carrying goods can be identified, the default should be that they are cars.Ìý

Going forward, classification of double cab pickupsÌý(including variants such as extended, extra, king and super cab pickups etc)Ìýwill therefore need to be determinedÌýbyÌýassessing the vehicle as a whole atÌýthe point that it is made available to determineÌýwhetherÌýthe vehicle construction has a primary suitabilityÌýas per the two-part test outlined atÌýEIM23115Ìýonwards.ÌýIt therefore follows that from 6 April 2025 most double cab pickupsÌýare expected to be classified as cars when calculating the benefit charge.ÌýThis is because typicallyÌýthese vehicles are equally suited to convey passengers and goods and have no predominant suitability.Ìý

The VAT input tax position remains unchanged as outlined at VIT56600.ÌýÌý

Transitional arrangementsÌý

Transitional arrangements will apply for employers that have purchased, leased, or ordered a double cab pickup before 6 April 2025, whereby they will be able to rely upon the previousÌýtreatment until the earlier of disposal, lease expiry, or 5 April 2029.  The position prior to 6 April 2025 remainsÌýunchanged as outlined at EIM23150.Ìý

The following examples all relate to double cab pickups made available to employees, that are not of a construction primarily suited for the conveyance goods or burden;Ìý

Example 1 â€� Employer A purchasedÌýa double cab pickup (extended model) on 14 September 2025.ÌýAs purchases on orÌýafter 6 April 2025 would be subject to the new rules, in this example the vehicle would be classified as a car and a car benefit charge would arise.Ìý

Example 2 â€� Employer B leased a double cab pickup on 10 December 2024.ÌýAs this was leased before 6 April 2025, the previousÌýrules continue to apply for Employer B until the earlier of the lease expiry, or 5 April 2029.Ìý

Example 3 â€� Employer C purchasedÌýa double cab pickup on 10 January 2024. This was subsequentlyÌýtraded in on 10 April 2025 for another double cab pickup. The previousÌýrules apply to the first vehicle for Employer C until the trade in point on 10 April 2025. As the new double cab pickup was purchasedÌýafter 6 April 2025 it will representÌýa car under the new rules and a car benefit charge would arise.Ìý

Example 4 â€� Employer D placed an order for a double cab pickup on 5 January 2025, but this was not available to the employer until 2 September 2025. As the agreement was entered into before 6 April 2025, the previousÌýrules continue to apply for Employer D until the earlier of disposal, lease expiry, or 5 April 2029.ÌýÌý

For the tax treatment of double cab pickups from 6 April 2002 to 5 April 2025 please see EIM23150ÌýÌýÌý

In case of difficulty see EIM23160