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HMRC internal manual

Employment Income Manual

HM Revenue & Customs
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Car benefit calculation Step 5, appropriate percentage: approved CO2 emissions figure: cases of difficulty

This page relates to step 5 of the method statement in Section 121(1) ITEPA 2003, see EIM24015. It will help in understanding the guidance following this paragraph if you are familiar with the guidance at EIM24505 explaining the term approved CO2 emissions figure.

Car first registered from 1 March 2001 onwards

There should be few difficulties in identifying the approved CO2 emissions figure for cars first registered in the UK from 1 March 2001 onwards, as the new car registration certificate (V5C) records the approved CO2 emissions figure, see EIM24515. See:

  • EIM24520 about cars imported from within the EU
  • EIM24525 about cars imported from outside the EU and
  • EIM24530 about more unusual models.

Car first registered from 1 January 1998 to 28 February 2001

For cars in this category there will almost always be an approved CO2 emissions figure. But as it is not recorded on the car registration document (V5) the employer will often have to seek information from one of the sources described at EIM24505. This should not normally be a problem provided that the employer has correctly identified the key features of the car in question (model, engine size, fuel type, etc).

However, there have been a few occasions when employers have found what appears to them to be contradictory information on the SMMT and VCA databases about the approved CO2 emissions figure for the same car. The figures should normally be the same. The figures in both databases are collected from the manufacturer. For this reason there is no need for an employer to check both databases once he or she has found the car and model details for a car of the same type. (See EIM24505 about what constitutes a type of car for CO2 purposes).

However, if an employer does find an apparent discrepancy:

  • ensure that the employer has correctly identified the model/type details of the car in question
  • check that the employer is using an appropriate database. Remember that, as the VCA figures relate to new cars currently on sale in the UK, employers will not be able to use the VCA internet database to find the approved CO2 emissions figure for a car sold as new, for example, two years ago. (However, the version of the VCA booklet that was current at the time a car was first registered will provide a useful historical record). If after carrying out these checks there is still a small discrepancy, the employer can use the lower CO2 emissions figure to calculate the car benefit charge.
  • if, after carrying out these checks there is a large discrepancy, you should obtain full details of the make and model of the car and of the conflicting CO2 emissions figures(This content has been withheld because of exemptions in the Freedom of Information Act 2000) .

Car first registered before 1 January 1998

Car benefit is always based on engine size and not on CO2 emissions figures, even if (exceptionally) they exist, see EIM24975.