Double cab pickups: car or van for tax

From 6 April 2025 HMRC stopped using the one tonne payload test for double cab pickups, so most of them are now treated as cars for benefit in kind. The same change applies to capital allowances for expenditure on or after 1 April 2025 (companies) or 6 April 2025 (unincorporated businesses), so new purchases no longer qualify for the annual investment allowance or full expensing. Transitional rules protect vehicles bought, leased or ordered before those dates for a limited period.

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What changed, and why?

Since 6 April 2002 HMRC had followed the VAT approach: a double cab pickup with a payload of one tonne (1,000kg) or more was accepted as a van, and one below that was a car. EIM23150 explains that payload means gross vehicle weight less unoccupied kerb weight, and that by agreement a hard top counted as 45kg, so fitting one could tip a vehicle just over the line into being a car.

In 2020 the Court of Appeal decided Payne and others (Coca Cola) v HMRC, a case about other multi purpose vehicles. EIM23151 says that judgment showed a finely balanced payload test was at odds with the “primary suitability” test in section 115 of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA), and that where no clear predominant suitability for goods can be found the default is that the vehicle is a car.

HMRC first announced in February 2024 that the change would apply from 1 July 2024, then withdrew it a week later, saying the government would legislate to keep the old treatment. At Autumn Budget 2024 the government decided not to legislate. The Budget’s overview of tax legislation and rates (paragraph 2.19) confirms that double cabs with a payload of one tonne or more will be treated as cars for capital allowances, benefits in kind and some deductions from business profits, with transitional arrangements.

How is a double cab pickup classified now?

Section 115 ITEPA defines a car by exclusion: a vehicle “of a construction primarily suited for the conveyance of goods or burden of any description” is not a car. EIM23115 sets out a two part test. First identify the vehicle’s construction when it is made available, including any modifications that are permanent and substantial. Then ask whether that construction is primarily suited to carrying goods.

EIM23121 records the Court of Appeal’s view that “primarily” means first and foremost, not a 51% to 49% margin, and that a multi purpose vehicle may have no primary suitability at all. A typical double cab has a second row of seats for about four passengers, four doors and an open load bed. EIM23151 says these are usually equally suited to passengers and goods, so from 6 April 2025 most will be classified as cars. This includes extended, extra, king and super cab variants. A single cab pickup with one row of seats is normally still accepted as a van.

Modifications can change the answer, but only if they alter the construction. EIM23115 says sliding out the rear seats while leaving the mountings and seat belt fixtures, or covering the rear windows temporarily, does not. Permanently removing the rear seats and fittings, welding in a load floor and replacing the rear side glass with fixed panels may.

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What are the benefit in kind transitional rules?

EIM23151 lets an employer that purchased, leased or ordered a double cab pickup before 6 April 2025 keep the old payload treatment until the earliest of:

disposal of the vehicle;
expiry of the lease; or
5 April 2029.

The protection follows the employer and the vehicle, not the employee. Moving a protected pickup from one employee to another between 6 April 2025 and 5 April 2029 does not lose the van treatment. However, HMRC’s example 6 shows that if a lease expires and the employer takes a new lease on the same vehicle, it becomes a car from the start of the new lease. A vehicle ordered before 6 April 2025 but delivered later is protected because the agreement came first. A pickup traded in after 6 April 2025 for a new one loses protection: the replacement is a car.

How much more tax does the employee pay?

As a van, a pickup with more than insignificant private use carries a flat van benefit, which is £4,170 for 2026 to 2027, plus £798 if private fuel is provided. As a car, the benefit is the list price multiplied by the appropriate percentage for its CO2 emissions, which reaches the 37% maximum at the top of HMRC’s 2026 to 2027 tables. Private fuel adds a car fuel benefit of the same percentage of £29,200.

Illustration only. A double cab with a list price of £40,000 at the 37% rate gives a car benefit of £14,800, against a van benefit of £4,170. With free private fuel the fuel benefit becomes £10,804 (37% of £29,200) instead of £798. A higher rate taxpayer would pay several thousand pounds more income tax, and the employer pays Class 1A National Insurance at 15% on the larger figure. The car rules are explained in company car tax, and the van rules in company van benefit.

What changed for capital allowances?

Capital Allowances Manual CA23511 applies the same reasoning to the definition of a car in section 268A of the Capital Allowances Act 2001. For expenditure incurred on or after 1 April 2025 (Corporation Tax) or 6 April 2025 (Income Tax), HMRC expects most, if not all, double cab pickups to be cars. A car does not qualify for the annual investment allowance or full expensing; writing down allowances at the main or special rate, depending on CO2 emissions, are given instead, as explained in capital allowances on cars.

The capital allowances transitional rule is narrower than the benefit in kind one. It covers expenditure under a contract entered into before 1 April 2025 or 6 April 2025, but only if the expenditure is incurred before 1 October 2025. HMRC’s example in CA23511 shows a company that signed a contract and paid a deposit in January 2025 and paid the balance on collection in June 2025: both amounts kept goods vehicle treatment. A pickup contracted for in September 2025 is a car. Pickups with a payload under one tonne were always cars and nothing has changed for them.

What about hire costs and the cash basis?

Business Income Manual BIM47730 applies the change to the restriction on hiring costs for cars with CO2 emissions above 50g/km. Hire expenditure on a double cab on or after 1 April 2025 or 6 April 2025 is treated as hire of a car. There is a transitional rule for hire contracts entered into before those dates, but only for expenditure incurred before 1 October 2025; after that, the car rules apply regardless of when the contract was signed. Under the cash basis, BIM70035 confirms that capital expenditure on a car is not deducted as an expense, although capital allowances remain available unless the business mileage rate has been claimed.

Does it affect VAT or vehicle excise duty?

No. EIM23151 states that the VAT input tax position is unchanged, so the payload test still governs VAT recovery (see VAT on cars, vans and fuel), and that the change does not affect how vehicle excise duty is calculated. A pickup can therefore be a car for income tax and capital allowances while still being a commercial vehicle for VAT.

What mistakes come up most often?

Assuming a pickup with a payload over one tonne is still a van because the dealer’s brochure or the VAT treatment says so.
Treating the transitional rules as identical: protection for benefit in kind can run to 5 April 2029, but capital allowances protection ended for expenditure on or after 1 October 2025.
Renewing a lease on a protected vehicle without realising it becomes a car from the new lease start.
Relying on removable seat changes or temporary window covers to argue the vehicle is a goods vehicle.
Forgetting that a pickup reclassified as a car brings fuel into the much higher car fuel benefit rules.

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Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 19 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.