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HMRC internal manual

Employment Income Manual

HM Revenue & Customs
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Car benefit calculation Step 1, price of the car: carbon offset charges

Section 123 ITEPA 2003

The term ‘list price’ is defined at EIM24105. The definition includes the words ‘inclusive price’, a term which carries its normal English meaning.

Some manufacturers and importers mention Carbon Offset Charges to buyers of new cars. These are handled in two ways which affect whether the charge is included in the list price for car benefits purposes.

The charge is payable (the customer may be able to opt out)

Because the list price is the ‘inclusive price’, the carbon offset charge is included in the list price for car benefits purposes in this case. This is so whether it is included in the published list price or added to it. The option available to the customer (if they have one) is not to pay it or, put another way, the customer has to take action to avoid paying it.

Even if the customer opt outs and does not pay the charge, it is still included in the list price for car benefits purposes. This is because this option is treated in the same way as a discount. No other discount to the inclusive list price affects the price for car benefit purposes; the same is true for carbon offset charges from which the customer can opt out.

The charge is not payable unless the customer opts in

Here, the charge is not part of the ‘inclusive price’. As a result, it does not form part of the list price for car benefits purposes.

The option available to the customer is whether to pay it. They will not have to pay it unless they take action to do so.

Because no accessory is acquired as a result of paying the charge, neither is it within the kinds of amount to be taken into account under Step 2 (EIM24200 onwards).

Voluntary carbon offset payments after the car is purchased

Owners of cars purchased before the Carbon Offset Charge was introduced are sometimes offered the chance to purchase an identical or similar package. Such purchases are ignored for car benefit purposes because:

  • they are not part of the list price because the package was not available from the manufacturer at the time the car was purchased
  • they are not accessories because they are not capable of being “attached to the car”, Section 125(2)(c).