EIM23151 - Car benefit: double cab pickups 6 April 2025 onwards
Source: gov.uk (2025-02-20)


For the tax treatment of double cab pickups from 6 April 2002 to 5 April 2025 please see EIM23150 (https://www.gov.uk/hmrc-internal-manuals/employment-income-manual/eim23150)

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

This finely balanced test is at odds with the Court of Appeal ruling in Payne & Ors (Coca-Cola) v R & C Commrs (2020) BTC19 (see EIM23121 (https://www.gov.uk/hmrc-internal-manuals/employment-income-manual/eim23121)), which clarified the correct application of the “primary suitability” test under Section 115 ITEPA 2003. The ruling established 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.

Going forward, classification of double cab pickups (including variants such as extended, extra, king and super cab pickups etc) will therefore need to be determined by assessing the vehicle as a whole at the point that it is made available to determine whether the vehicle construction has a primary suitability as per the two-part test outlined at EIM23115 (https://www.gov.uk/hmrc-internal-manuals/employment-income-manual/eim23115) onwards. It therefore follows that from 6 April 2025 most double cab pickups are expected to be classified as cars when calculating the benefit charge. This is because typically these vehicles are equally suited to convey passengers and goods and have no predominant suitability.

The VAT input tax position remains unchanged as outlined at VIT56600 (https://www.gov.uk/hmrc-internal-manuals/vat-input-tax/vit56600).

Transitional arrangements

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 treatment until the earlier of disposal, lease expiry, or 5 April 2029. The position prior to 6 April 2025 remains unchanged as outlined at EIM23150 (https://www.gov.uk/hmrc-internal-manuals/employment-income-manual/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 the lease has not expired.

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;

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

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

Example 3 – Employer C purchased a double cab pickup on 10 January 2024. This was subsequently traded in on 10 April 2025 for another double cab pickup. The previous 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 after 6 April 2025 it will represent a car under the new rules and a car benefit charge would arise.

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

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

Example 6 – 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 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 (https://www.gov.uk/hmrc-internal-manuals/employment-income-manual/eim23150)

In case of difficulty see EIM23160 (https://www.gov.uk/hmrc-internal-manuals/employment-income-manual/eim23160)