Taking an emergency vehicle home: the tax exemption

Police, fire and rescue, and ambulance staff who take an emergency vehicle home are not taxed on it if the vehicle is provided mainly for business travel and the terms allow private use only while they are on call or commuting. The exemption is in section 248A of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA). Since the tax year 2017 to 2018, ordinary commuting is allowed even when the person is not on call, but any other private use takes the vehicle outside the exemption.

Tax investigation insurance from £108.75 a year (£9.06 a month).Pays up to £100,000 of your accountant's fees if HMRC opens an enquiry. No excess. Buy online in a few minutes.

See my price in 2 questions How the cover works Accountant? Offer cover to your clients or call 01795 841 310

Why would an emergency vehicle be taxable at all?

A vehicle fitted with a fixed flashing blue light is generally not a “car” for car benefit purposes. In Gurney v Richards (62 TC 287) a chief fire officer’s Ford Sierra with a fixed flashing light was held to be a type of vehicle not commonly used, and unsuitable to be used, as a private vehicle. HMRC accepts this at EIM23140. But that only removes the car benefit charge. If the vehicle is also available for private use, a residual charge can arise under the general benefits code in section 203 ITEPA, and taking the vehicle home is ordinary commuting, which is private use. Section 248A was introduced by Finance Act 2004 to stop that charge, and HMRC says at EIM23600 that its purpose is to improve emergency response times, not to provide free benefits.

Who is covered by the exemption?

Section 248A(4) limits it to people employed in an emergency service:

constables and other persons employed for police purposes;
persons employed for the purposes of a fire, or fire and rescue, service; and
persons employed in the provision of ambulance or paramedic services.

HMRC reads “fire and rescue” as a single term, so vehicle breakdown and similar rescue services are excluded (EIM23600). The Treasury can amend the list by order under section 248A(5). Other employees who respond to emergencies, such as utility engineers, have to rely on the ordinary rules, for example the van benefit rules or the exemption for pool cars.

Worried about an HMRC check? Tax investigation insurance pays your accountant’s fees if HMRC opens an enquiry or compliance check. Solar Protect cover pays up to £100,000 with no excess. It never pays tax, interest or penalties.

From £108.75 a year (£9.06 a month) for individuals, £117.57 for sole traders and £207.50 for companies and partnerships, including IPT and the £20 admin fee.

See my price in 2 questions or call 01795 841 310.

★★★★★ Rated 4.9 out of 5 on Trustpilot from over 160 reviews

What counts as an emergency vehicle?

Section 248A(3) defines an emergency vehicle as one used to respond to emergencies which either has fixed to it a lamp designed to emit a flashing light for emergency use, or would have one but for the fact that this would create a special threat to the personal security of the people using it by revealing that they work for an emergency service. The second limb covers unmarked vehicles used where being identified would be dangerous.

EIM23600 says “fixed” means a permanent fitting. It need not be on the outside of the vehicle, but a vehicle with only a removable light is not an emergency vehicle for this purpose. The type of vehicle is not defined, so a car or a van can qualify, and HMRC confirms the guidance applies equally to van benefit (EIM22775).

What private use is allowed?

Under section 248A(1) the vehicle must be made available mainly for use for the person’s business travel, the terms must prohibit private use other than when the person is on call or commuting, and the person must not in fact make any other private use of it. “Private use” means any use other than business travel as defined in section 171(1).

The two permitted kinds of private use are:

On call. Section 248A(7) says a person is on call when they are liable, as part of their normal duties, to be called on to use the vehicle to respond to emergencies. EIM23605 says use while on call is not limited to commuting, but in practice it can only be reasonably local to where the person lives and works, since otherwise they could not respond.
Commuting. Section 248A(8) covers ordinary commuting, or travel between two places that is for practical purposes substantially ordinary commuting.

Anything else, such as a family holiday or a weekend trip while off duty, is private use outside the permitted categories, and the exemption fails.

What changed from April 2017?

Section 9 of Finance Act 2019 amended section 248A with effect for 2017 to 2018 and later years. Before that, the vehicle had to be made available for the person’s private use, and private use was permitted only when on call or when engaged in what the legislation called on call commuting. The amendment replaced the first test with the “mainly for business travel” test and removed the on call qualification from commuting, so ordinary commuting is now permitted in its own right. HMRC explains at EIM23600 that the change was made to support the work of the emergency services.

What happens if the exemption does not apply?

Where the conditions are not met, a charge arises on the vehicle as an asset made available without transfer under section 205 ITEPA. For 2017 to 2018 through 2019 to 2020 only, Finance Act 2019 allowed the older private mileage ratio method to continue for emergency vehicles (EIM23610). From 6 April 2020 the normal rules for assets made available apply.

Fuel has its own relief. Section 205(5), inserted by Finance Act 2019, says the cost of fuel for an emergency vehicle is not an additional expense in the benefit calculation if the employer provides no private fuel in the tax year, or if the employee makes good all private fuel on or before 6 July following the tax year (EIM23615). Fuel includes electricity.

What about National Insurance and reporting?

HMRC’s National Insurance Manual at NIM14110 lists emergency vehicles under section 248A among benefits exempt from income tax and Class 1A National Insurance, so an exempt vehicle needs no P11D entry. Where the exemption fails, EIM23610 says the value of the benefit is reported on a P11D in the normal way; see benefits in kind and form P11D.

How does this work in practice?

Illustration only. A rapid response paramedic is given a liveried estate car with fixed blue lights. The trust’s vehicle policy says it is provided for operational use, may be driven home and back, and may be used locally while the paramedic is on call, but not otherwise. One week she is on call and stops at a supermarket near home on the way back from a callout: that is permitted on call use. The following month, on a rest weekend, she uses the car to drive her children to a match 80 miles away. That is private use outside the exemption, so for that tax year the vehicle is chargeable under section 205.

What mistakes come up most often?

Relying on a removable magnetic beacon, which does not make the vehicle an emergency vehicle.
Vehicle policies that are silent on private use instead of prohibiting it except when on call or commuting.
Assuming the exemption covers non statutory responders, such as breakdown crews.
Not keeping evidence of on call rotas, which show that private journeys were made while on call.
Missing the 6 July deadline for making good private fuel.

If HMRC opens a check into your return, tax investigation insurance pays your accountant’s fees. Solar Protect cover pays up to £100,000 with no excess; it never pays tax, interest or penalties. Read how our cover works or get a quote.

Related Accountapedia entries

Sources

Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 24 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.