CA23511 - Plant and Machinery Allowances (PMA): cars: double cab pick-ups

CAA01/S268A

Expenditure incurred before 1 or 6 April 2025

For expenditure incurred before 1 April 2025 for Corporation Tax and 6 April 2025 for Income Tax, a double cab pick-up with a payload of one tonne or more is not to be treated as a car ('payload' is the difference between a vehicle’s maximum gross weight and its kerbside weight) – CA23510. 

Expenditure incurred on or after 1 or 6 April 2025

For expenditure incurred on or after 1 April 2025 for Corporation Tax and 6 April 2025 for Income Tax, HMRC will no longer interpret the legislation that defines a car for capital allowances purposes as excluding double cab pick-ups with a payload of one tonne or more. Section 268A(1)(b), which excludes from the definition of a car “a vehicle of a construction primarily suited for the conveyance of goods or burden of any description”, will be interpreted in accordance with the guidance at CA23510. It follows that most, if not all, double cab pick-ups, which are equally suited to convey passengers or goods, will be classified as cars.

Transitional arrangements

Transitional arrangements will apply when an amount of expenditure is incurred on a double cab pick-up as a result of a contract entered into before 1 April 2025 for Corporation Tax and 6 April 2025 for Income Tax and the expenditure is incurred on or after that date but before 1 October 2025. In these circumstances a double cab pick-up with a payload of one tonne or more will continue to not be treated as a car.

Example 1

New Morning Floral Designs Limited enters into a contract on 1 January 2025 to purchase a double cab pick-up (payload 1,075kg) from Oxford Town Motors Limited for its expanding delivery service. The total cost of the vehicle is £35,000. They pay a 10% deposit of £3,500 on 1 January 2025, the day they sign the contract. The vehicle is available for collection on 1 June 2025 and the company pays the balance of £31,500 on collection. The deposit of £3,500 is incurred on 1 January 2025, before the commencement of the revised interpretation for double cab pick-ups. Accordingly, this will be expenditure incurred on the provision of a goods vehicle and the company may be entitled to claim annual investment allowance or full expensing.

The balance of £31,500 is incurred on 1 June 2025, which is on or after 1 April 2025, when the revised interpretation for double cab pick-ups applies for companies. However, this expenditure has been incurred in respect of a contract entered into before 1 April 2025 and, as a result, the pre-1 April 2025 interpretation will apply.

Example 2

New Morning Floral Designs Limited’s delivery service goes from strength to strength. On 1 September 2025 the company enters into a contract to purchase a further double cab pick-up, paying the full price of £38,000 at that time and taking delivery one week later. The expenditure is incurred on 1 September 2025, which is on or after 1 April 2025, and as a result of a contract entered into after that date, so the new interpretation will apply. Accordingly, the purchase is likely to be treated as on the provision of a car for PMA purposes, and the expenditure will not qualify for the annual investment allowance or full expensing.

Double cab pick-ups - payload under one tonne

The application of the definition of a car to double cab pick-ups with a payload of under one tonne has not changed. It is expected that these vehicles are not primarily constructed for the conveyance of goods or burden of any description. Accordingly, these vehicles will continue to be treated as cars.