CA23510 - Plant and Machinery Allowances (PMA): cars: outline - meaning of ‘car’

CAA01/S268A

For expenditure incurred on or after 1/6 April 2009, the capital allowances treatment is determined by the car’s carbon dioxide emissions (CA23535).

Meaning of 'car'

For PMA purposes a car is a mechanically propelled vehicle other than:

  • a motor cycle
  • a vehicle of a construction primarily suited for the conveyance of goods or burden of any description, or
  • a vehicle of a type which is not commonly used as a private vehicle and is not suitable for use as a private vehicle.

Treat a car that is capable of being used as a private vehicle as a car for PMA purposes no matter how the taxpayer actually uses it (Roberts v Granada TV Rental Ltd 46TC295).

Treat small limousines, that is those with fewer than 9 passenger seats, as cars for PMA purposes.  Although such vehicles may be of a type that is not commonly used as a private vehicle, they are suitable for such use.  Limousines that are not considered small may still be cars, it is necessary to consider the facts of each case.

To determine whether a vehicle is of a construction primarily suited for the conveyance of goods or burden of any description, it is necessary to see if there is a predominant purpose of construction. It is necessary to consider the facts of each case, but if a vehicle is designed and marketed as a multi-purpose vehicle, it is likely to be a car. If a vehicle is constructed or adapted for more than one purpose and neither purpose predominates, then it is likely to be a car (Payne & Ors (Coca-Cola) v R & C Commrs (2020) (BTC19)).

Do not treat the following vehicles as cars for PMA purposes:

  • A car that it is illegal for a taxpayer to use as a private vehicle even if the taxpayer sometimes uses it as a private vehicle (Gurney v Richards 62TC87).
  • Cars used by a driving school and fitted with dual control mechanisms (Bourne v Auto School of Motoring (Norwich) Ltd 42TC217)
  • Emergency vehicles. A vehicle equipped with a fixed blue flashing light on the roof which can only be used on the road by a fire officer or police officer is an emergency vehicle.
  • Hackney carriages ( traditional ‘London black cab’ type vehicles).
  • Double cab pick-ups with a payload of one tonne or more if the expenditure is incurred before 1 April 2025 for Corporation Tax and 6 April 2025 for Income Tax. If the expenditure is incurred on or after 1/6 April 2025 see CA23511. (Payload is the difference between a vehicle’s maximum gross weight and its kerbside weight).

A motor cycle is defined (in the Road Traffic Act of 1988) as a mechanically propelled vehicle, other than an invalid carriage, with less than four wheels. The unladen weight must not be more than 410 kilograms.

Quadricycles (quadbikes) do not meet the definition of a ‘motorcycle’. If they are road vehicles within the definition above then they will be treated as cars for capital allowances purposes.

There is guidance on number plates at CA21250.

Self-employed taxpayers may use mileage rates to compute their vehicle expenses, including capital allowances, if the annual turnover of the business is less than the VAT registration threshold. Further guidance can be found at BIM75005.