HMRC reclassifies farm pickups in major change to vehicle tax

Farmers must now navigate the tax landscape with care and consider how the vehicle is used
Farmers must now navigate the tax landscape with care and consider how the vehicle is used

A landmark tax ruling, with significant implications for farmers, has seen the classification of double-cab pickups officially change from vans to cars.

This latest decision follows a dispute between Coca-Cola and HM Revenue & Customs (HMRC), which stems from a legal battle dating back to 2017.

It closes a loophole that previously allowed these vehicles to enjoy lower Benefit in Kind (BIK) tax rates and VAT reclaim benefits.

Historically favoured for their versatility and cost-effectiveness, double-cab pickups with a payload of one tonne (1,000kg) or more were previously classified as vans for taxation purposes.

However, an earlier ruling in 2020 (Payne & Ors (Coca-Cola) v R & C Commrs) by HMRC on the definition of a van has led to a significant shift.

From 1 July 2024, most double-cab pickups are likely be considered cars due to their dual functionality, thus attracting higher taxes for their users.

Owners of double-cab pickups used for business, including many farmers, must now navigate the tax landscape with care and consider how the vehicle is used.

This includes for business use: The possibility to claim capital allowances and reclaim VAT, subject to HMRC's conditions.

And for mixed use: The need to account for VAT on the private use portion and prepare for a BIK tax charge based on CO2 emissions and list price.

Owners who acquired their vehicles before this date may continue to benefit from the current tax rules until 5 April 2028 or until the vehicle is sold, depending on which comes first.

Given the changes, tax firm Moore Thompson has emphasised the importance of establishing clear vehicle usage agreements to demonstrate the intended purpose of vehicles to HMRC

Heather Bright, a tax partner at Moore Thompson, advised the farming community on the implications of this change.

She said: “This landmark ruling marks a pivotal shift in how double-cab pickups are perceived for tax purposes. Farmers and small businesses that have relied on these vehicles for their dual-use benefits must now reassess their tax strategy moving forward.

“It's crucial to understand the impact on both capital allowances and BIK tax charges, depending on whether the vehicle is used exclusively for business or mixed use."

Ms Bright said that the new tax classification change may present an opportune moment for the farming community to consider transitioning to electric vehicles (EVs).

While practicality and the availability of suitable vehicles will need to be considered, she said there are numerous benefits to operating an electric van or truck, including Enhanced Capital Allowances, lower BIK rates, and eligibility for the Zero Emissions Goods Vehicle Grant.

“However, we fully appreciate the realities of modern farming and understand the value that many farmers place on double-cab pickups," Ms Bright explained.

“Nevertheless, given these changes, they really must assess whether operating such as vehicle in their fleet makes sense from a tax and cost perspective going forward.”