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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 鈥渃ar鈥� and 鈥渧补苍鈥� for tax purposes with the definitions used for VAT purposes.听Under the VAT approach double cab pickups are classified based on payload capacity, with anything under one tonne听classified as a car, and anything a tonne听and over as a van. This rule was replicated as a pragmatic way of resolving the primary suitability and classification of double cab pickups.听听听

This finely balanced听test is at odds with the Court of Appeal ruling in Payne & Ors (Coca-Cola) v R & C Commrs听(2020) BTC19 (see EIM23121),听which clarified the correct application of the 鈥減rimary suitability鈥� test under Section 115 ITEPA 2003.听The ruling established听that 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.听

Going forward, classification of double cab pickups听(including variants such as extended, extra, king and super cab pickups etc)听will therefore need to be determined听by听assessing the vehicle as a whole at听the point that it is made available to determine听whether听the vehicle construction has a primary suitability听as per the two-part test outlined at听EIM23115听onwards.听It therefore follows that from 6 April 2025 most double cab pickups听are expected to be classified as cars when calculating the benefit charge.听This is because typically听these vehicles are equally suited to convey passengers and goods and have no predominant suitability.听

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

Transitional arrangements听

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 previous听treatment until the earlier of disposal, lease expiry, or 5 April 2029. The position prior to 6 April 2025 remains听unchanged as outlined at EIM23150.

Where an employer transfers a double cab pickup between their own employees between 6 April 2025 and 5 April 2029 and the transitional arrangements already apply, they may continue treating it as a van for tax purposes, provided there is no disposal or听the lease has not expired.听

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;听

Example 1 鈥� Employer A purchased听a double cab pickup (extended model) on 14 September 2025.听As purchases on or听after 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.听

Example 2 鈥� Employer B leased a double cab pickup on 10 December 2024.听As this was leased before 6 April 2025, the previous听rules continue to apply for Employer B until the earlier of the lease expiry, or 5 April 2029.听

Example 3 鈥� Employer C purchased听a double cab pickup on 10 January 2024. This was subsequently听traded in on 10 April 2025 for another double cab pickup. The previous听rules apply to the first vehicle for Employer C until the trade in point on 10 April 2025. As the new double cab pickup was purchased听after 6 April 2025 it will represent听a car under the new rules and a car benefit charge would arise.听

Example 4 鈥� 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 previous听rules continue to apply for Employer D until the earlier of disposal, lease expiry, or 5 April 2029.听

Example 5 鈥� Employer E leased a double cab pickup on 2 February 2025 and made it available to Employee A on 5 February 2025.听The vehicle was then transferred to Employee B on 9 September 2025.听As this was leased before 6 April 2025, the鈥�previous鈥痳ules continue to apply for Employer E until the earlier of the lease expiry,听or 5 April 2029.鈥疉nd as the transitional arrangements apply, reallocating the vehicle to Employee B will not alter the vehicle鈥檚 classification as a van, provided the lease has not expired.听

Example 6 鈥� Employer F leased a double cab pickup on 1 November 2024 and made it available to Employee C on 4 November 2024. The lease agreement expired on 31 October 2026. Employer F decided to enter into听a new lease for the same vehicle on 1 November 2026 and this was made available to Employee D on 2 November 2026. As the lease ended on 31 October 2026, the vehicle will be classified as a car from 1 November 2026 onwards.

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

In case of difficulty see EIM23160