BUSINESS CAR TAXATION - BVRLA POLICY PAPER MARCH 2016
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The average annual One fifth of company car tax bill has company car drivers risen by 12% since 2005-06, but are paid under total company car £30,000 p.a. tax revenues have fallen by 7.5% in the same period. The number of Company Car drivers has fallen from 970,000 in 2009-10 to 940,000 in 2013-14. The total average The 2 percentage point rise in Company Car Tax tax revenue per salary bands from 2017, plus the continuation sacrifice car is £4,508.11, of the 3% diesel surcharge, with an overall estimated will add an extra £626.94 to the average £270,486,600 received by company car driver’s bill in 2017-18 HMRC in tax revenue compared to 2013-14 - per year via salary a 15.43% increase. sacrifice arrangements. 2
B V R L A p o l i c y p a p e r – b u s i n e s s c ar t a x a t i o n Introduction As the representative body of a major tax contributing sector, the British Vehicle Rental and Leasing Association (BVRLA) engages regularly with Government to discuss policy changes related to the tax regime. The UK vehicle rental and leasing sector has long demonstrated its value as a contributor to the economy, purchasing an estimated one million vehicles (including 308,000 UK-made vehicles) per annum, generating £24.9 billion in gross value added for the UK economy and employing 53,600 people. As a result of the activities supported by the UK rental and lease sector in 2013, the Treasury received a total £5.2 billion in total tax revenue1. Both the BVRLA and its members understand the importance and necessity of taxation, especially in the years following the Global Financial Crisis, and in meeting the subsequent challenge laid down by the Chancellor of bringing down the national deficit. Recent changes to company car tax, announced in the 2015 Autumn Statement, and ongoing discussions around the future of initiatives such as salary sacrifice - including a mention in Budget 2015 - have had an impact on the behaviour of business car drivers, and the practices of vehicle providers in the lease and brokering sectors. In particular, BVRLA members have expressed concern at the Chancellor’s decision to continue the 3% Company Car Tax surcharge on diesel vehicles, at a time when Company Car Tax bands are due to rise by 2% from 2017, and the effect that this could have on the numbers of employees choosing to take a company car. The purpose of this paper is to therefore provide an industry view on the current business car sector, alongside an analysis of recent changes to the tax system and the effects these have or are likely to have upon employers, employees with company cars, and the vehicle lease sector. Finally, a series of policy proposals are included, recommending how HM Treasury and the Government might achieve a “win-win” situation, namely a tax positive revenue alongside a stable and confident business sector. Contents 4 Company car and company fuel tax 6 The individual effect company car and company fuel tax increases 8 The 3% diesel supplement 10 Benefit in kind ratings 10 First year capital allowances 11 Electric vehicles 12 Whole Life cost comparions - 10,000 miles per year 14 Whole Life cost comparions - 20,000 miles per year 16 Salary sacrifice 18 Fuel duty 19 Summary of recommendations 20 Participating organisations 1 The Economic Impact of the Motor Vehicle Full-Service Leasing and Renting Sector (Oxford Economics, November 2014) at: http://www.bvrla.co.uk/sites/default/files/ documents/economic_impact_of_the_rental_and_leasing_sector.pdf 3
Taxation issue Company car tax and company car fuel tax According to available data from HMRC2, there has been a steady reduction over the past ten years in the number of company car tax drivers, though the taxable revenue per recipient has steadily increased. The number of recipients of company car fuel has also diminished, with the total tax revenue consequently being reduced by 29.5%. Table 1: Company car and fuel tax revenue versus contributions per recipient Company car TAX Company car fuel TAX Year Company Total tax Taxable Company car Total tax Taxable car drivers revenue revenue per fuel recipients revenue revenue per (thousand) (£million) recipient (thousand) (£million) recipient 2005-06 1,140 4,130 £3,623 380 1,050 £2,763 2006-07 1,160 4,030 £3,474 360 970 £2,694 3 1,120 4,060 £3,625 340 900 £2,647 2007-08 2008-09 1,010 3,840 £3,802 300 950 £3,167 2009-10 970 3,740 £3,856 270 840 £3,111 2010-11 950 3,660 £3,853 250 810 £3,240 2011-12 950 3,610 £3,800 240 770 £3,208 2012-13 940 3,730 £3,968 220 770 £3,500 2013-14 940 3,820 £4,064 200 740 £3,700 2 HMRC; Taxable benefits in kind: Recipients, taxable value and income tax and NICs liability, by category, 2005-06 to 2013-14, at: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/456660/Table_4_5_2005-06_to_2013-14.pdf 3 The BVRLA acknowledges that the basis of calculating company car drivers and car fuel recipients changed in 2007-08. 4
B V R L A p o l i c y p a p e r – b u s i n e s s c ar t a x a t i o n Since the Chancellor took office in 2010, Graph 1: Company car tax, 2005-06 to 2013-14 Treasury revenue from company car tax has increased by £80 million. In the same timeframe, company car tax has risen by £204 4500 Total Tax Revenue Car (£m) £4,064 4,200 per recipient (5.19%) on average. Perhaps £3,856 £3,968 4,100 as a result of this increasing tax burden, 4000 £3,692 Tax revenue per recipient (£m) Tax revenue per recipient (£m) 4,000 the number of UK company car drivers has £3,474 £3,802 £3,853 3500 3,900 fallen by 30,000. In the same timeframe, the £3,625 £3,623 £3,800 3,800 number of recipients of company car fuel has 3000 3,700 decreased by approximately 70,000, with a 2500 3,600 resulting loss of £100 million in tax revenue. 3,500 However, company car fuel tax has increased 2000 3,400 by £589 per recipient, a rise of 18.9%. 1500 3,300 2005-06 2007-08 2008-09 2010-11 2012-13 2013-14 In addition, a further increase of 2 percentage est points per Company Car Tax band was also announced at Budget 2014, to come into force in 2017-18, with Treasury revenue estimated at £240 million in 2017-18, and £480 million in Graph 2: Company car fuel tax, 2005-06 to 2013-14 2018-194, as a result. This increase will therefore cost an additional £255.32 per recipient in 2017- 18 and £510.64 in 2018-19 – without taking into Total Tax Revenue Car Fuel (£m) 1,200 4000 £3,700 account the continuing decline in the number £3,500 of employees choosing to take a company car. 1,000 Tax revenue per recipient (£m) 3500 Total tax revenues (£m) These rises amount to an additional 6.28% 800 rise in 2017-18 and 12.57% in 2018-19 from 300 the most recent figures, or respective rises of 600 6.62% and 13.24% since the Chancellor took 2500 Taxable revenue per recipient (fuel) 400 office. 2000 200 As Graph 2 reveals, company car fuel tax has 1500 0 also risen, most dramatically in 2007-08, and 2005-06 2007-08 2008-09 2010-11 2012-13 2013-14 est with a further steady increase since 2011-12. This continuous increase has stabilised the decline in total tax revenue to the Treasury, but has resulted in an increase of £492 per recipient, a 15.34% rise. 4 HM Treasury; Budget 2014 document, p.57 at: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/293759/37630_Budget_2014_Web_Accessible.pdf 5
The individual effect of company car and company car fuel tax increases In quantifying the above statistics, the impact of the increase in the company car and company fuel tax burden on individual employees has been calculated according to data provided by HMRC5: Table 2: Company car and fuel recipients versus income6 Total income COMPANY Car TAX COMPANY Car fuel TAX Company Company Car Recipients Taxable value car drivers taxable value (thousands) (£ millions) (thousands) (£ millions) 0-£30,000 180 390 30 55 £30,001-50,000 370 1310 80 270 £50,001+ 370 2020 110 440 TOTAL 940 3730 220 770 As Table 2 demonstrates, approximately one fifth (19.15%) In terms of company car fuel tax, company car drivers of company car drivers are paid under £30,000 per annum. paid under £30,000 per annum make up 13.64% of all Their combined tax contribution was just over 10% recipients of company-paid fuel, which accounts for (10.46%) of total company car tax receipts for 2012-13. 7.14% of tax revenue for this. Drivers paid between Company car drivers paid between £30-50,000 per annum £30-50,000 make up 36.36% of the total, and account make up 39.36% of the total company car tax revenue for for 35.07% of the total tax company fuel tax revenue. the same period, paying 35.12% of total company car tax For drivers paid above £50,000, who account for receipts. Finally, the upper-end of company car tax drivers, approximately 50% of the total, these account for those paid £50,000 and above, also make up 39.36% of 57.14% of total company car fuel tax revenue. the total, and pay 54.16% of HM Treasury’s total company car tax revenue. 5 HMRC; Taxable benefits in kind: Analysis of company cars, employer-provided fuel and private medical insurance, by range of total income, 2012-13, at: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/456556/Table_4_3_2012-13.pdf NB: Numbers and amounts less than 10 are rounded to the nearest 5; those greater than 10 are rounded to nearest 10. As a result, the column totals may not equal the sum of individual components due to rounding. 6
B V R L A p o l i c y p a p e r – b u s i n e s s c ar t a x a t i o n Chart 1: Company car fuel – income versus tax From the figures revealed in Table 2, plus those displayed contributions in Chart 1, it appears that greater levels of tax revenue could be raised if more employees could be encouraged to take up a company car. The benefits of this would be two-fold – as well as increasing options for business 450 (many of which require the flexibility of a company car), 400 providing incentives for employees to take up a company 350 car can also provide a welcome boost for the sale of such 300 250 cars, around a third of which are manufactured in the UK.6 200 150 A further benefit of encouraging the take-up of company 100 cars is bringing greener and safer cars on to UK roads. 50 As BVRLA members’ vehicles are brand new and built 0 to the latest environmental standards, they are typically 1+ 0 00 00 cleaner, greener and produce lower emissions (including 00 ,0 0, 50 0, CO2, NOX or particulates) than the average vehicle on UK £3 £5 -£ 0- roads7, which is older and has a higher level of emissions. 1 00 In 2015, the average newly registered car emitted 122.1g/ 0, £3 km CO28. In comparison, according to the BVRLA’s Recipients (thousands) Taxable value (£ millions) most recent survey9, the average emissions of a BVRLA members’ newly registered lease car was 112.6g/km. The offer of a company car is particularly attractive to lower-paid employees, as this represents an opportunity to drive a safer and more fuel efficient new car. The risk in further increasing the tax obligations for such drivers is that they are likely to give up their company cars and instead use their own, older vehicles, which do not conform to the same safety or emissions standards. 6 The Economic Impact of the Motor Vehicle Full-Service Leasing and Renting Sector (Oxford Economics, November 2014) at: http://www.bvrla.co.uk/sites/default/files/documents/economic_impact_of_the_rental_and_leasing_sector.pdf 7 According to the SMMT report, “Motor Industry Facts 2015”, the average car on UK roads that year is 7.8 years old; p.26 at: http://www.smmt.co.uk/wp-content/uploads/sites/2/100049_SMMT-Facts-Guide-2015_UPDATES.pdf 8 According to the SMMT report, “New Car CO2 Report 2016”, the average car registered in 2015 emitted 121.4g/km CO2; p.3 at: http://www.smmt.co.uk/wp-content/uploads/sites/2/SMMT-New-Car-Co2-Report-2016.pd 9 BVRLA Quarterly Leasing survey – fleet CO2 emission trends, at: http://www.bvrla.co.uk/news/leasing-sector-leads-low-emission-charge 7
The 3% diesel supplement The Chancellor’s announcement in the 2015 Autumn Statement to delay the removal of the 3% differential between diesel and petrol cars from April 2016 to April 2021 has caused concern among the UK vehicle rental and leasing sector. While it is important to ensure confidence in the emissions performance of new vehicles, and equally important to allow time for the introduction of new and further EU emissions testing procedures, the perception is that the Government has penalised the innocent consumer with a highly punitive tax bomb. According to Treasury estimates10, the retention of the diesel supplement is calculated to increase tax revenue by £280 million in 2016-17, falling to £275 million in 2017-18 and 2018-19, and £265 million in both 2019-20 and 2020- 21, a total of £1.36 billion. Payment of these figures will therefore fall upon the 740,000 (out of a total 940,000) company car drivers who have opted in good faith to drive a lower emission diesel car over a petrol one, at least partly on the basis of the Chancellor’s announcement in 2012 that the supplement would be lifted in 2016. This means that the average company car driver of a diesel-engined car will pay an extra £378.38 in 2016- 17, £371.62 in 2017-18, £371.62 in 2018-19, £358.11 in 2019-20 and £358.11 in 2020-21. These additional payments represent an unexpected charge, based on the Chancellor’s previous assertion, and a penalisation of those drivers who have acted fairly, to balance the failing of the testing regime. 10 Autumn Statement 2015; Energy, environment and transport, p. 112, at: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/479749/52229_Blue_Book_PU1865_Web_Accessible.pdf 8
B V R L A p o l i c y p a p e r – b u s i n e s s c ar t a x a t i o n Combining these figures with the planned 2 percentage point increase per Company Car Tax band announced at Budget 201411 (which will come into force in 2017-18), the Treasury will receive additional company car tax revenue of £515 million in 2017-18, and £550 million in 2018-19. However, this translates to an additional £626.94 per recipient taking a company diesel car in 2017-18, and an extra £882.26 in 2018-20, once again assuming that the diminishing number of company car drivers remains unchanged. Therefore, these additional charges amount to a total 15.43% rise in 2017-18 and 21.71% in 2018-19 from the most recent figures, or respective rises of 16.26% and 22.88% since the Chancellor took office, per diesel company car. Such a sharp cumulative rise is unfair to these employees, many of whom have opted to drive some of the newest, safest, most fuel-efficient vehicles with low emissions. This also represents a further disincentive against the take-up or retention of company cars by employees. This decision could also further risk many employees deciding to give up their company cars altogether, in favour of personal contract hire or more likely, older, privately owned, higher emission vehicles. In order to limit this potential future effect, and maintain both the confidence of company car employees in both the consistency of the tax system and in the emissions testing regime, the BVRLA proposes that when employees decide to adopt an ultra-low emission vehicle as a company car - e.g.: those choosing a Euro 6C compliant vehicle before its mandatory introduction - the 3% diesel surcharge should be waived. This will provide a real incentive to employees to take up cars with the most advanced emissions standards, and would be a welcome encouragement to the company car regime. In addition, the 3% surcharge should also be removed on those cars that were ordered prior to the announcement of its continuation, to remove the unfair retrospective and unprecedented move of penalising drivers for decisions based on the published tax rates. 11 HM Treasury; Budget 2014 document, p.57 at: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/293759/37630_Budget_2014_Web_Accessible.pdf 9
Benefit-in-Kind ratings In order for Government to sustain the current vehicles attracting an 8% rating. level of company car tax revenue while By introducing greater granularity for vehicles with simultaneously reducing the tax burden on emissions levels between 1-50g CO2/km, mirroring the company car drivers, we recommend that the remaining ratings system by increasing exponentially the rating per every 5g CO2 emitted by the vehicle, this will Government consider a reform of the benefit- provide a greater incentive for employees to drive the in-kind (BIK) ratings. In particular, the BVRLA greenest car possible, and therefore promote the take up of would like to see greater granularity on the lower (if not ultra-low) emission vehicles over slightly higher emission ones. BIK ratings of vehicles which are at the lower category end. Reforming the benefit in kind ratings in this way can provide the opportunity for the Government to relieve the As the current ratings system demonstrates, petrol vehicles current tax burden on company car drivers – though any at the lower category end (vehicles with an emissions rating future change to the ratings system must be tax-neutral, of between 1-50g CO2/km) are currently given a rating of in order to sustain consumer confidence in the company 5% – identical to that of zero emission vehicles – with diesel car market. First year capital allowances In April 2013, the Government removed the The BVRLA believes that, for the reasons already stated, the withdrawal of FYAs has already had a dampening effect ability to claim 100% first-year allowances on demand for ultra low emission vehicles since 2013. on low-emission leased cars. Pure electric Leasing and rental are particularly attractive methods of vehicle finance for companies that are looking to adopt and plug-in hybrid cars are more expensive new technology, because the leasing and rental companies than their higher-emitting petrol and diesel take the ‘risk’ on the asset being hired. Companies can counterparts and such allowances could play in effect ‘try before they buy’ safe in the knowledge that they can just hand the vehicle back if the technology a major role in enabling potential buyers to doesn’t meet their needs. At the moment, the cost-gap bridge this cost gap. between EVs and petrol and diesel vehicles is curtailing this potential. The fact that these allowances are still available The leasing and rental industry purchases nearly 50% of for companies that purchase their assets outright all new vehicles registered in the UK each year, including more than 80% of those made in this country. Reinstating discriminates in favour of cash-rich businesses and against FYAs for our sector could provide a massive impetus to the others – particularly SMEs – who rely on lease finance to ultra-low emission vehicle market. fund their vehicle acquisition. HMRC officials have stated that this discrimination against leasing is necessary to prevent companies taking advantage of the allowances to acquire vehicles that are used outside of the UK. The BVRLA has yet to find any evidence of this threat, and also understands that HMRC has now identified a policy measure which could address it should it arise. 10
B V R L A p o l i c y p a p e r – b u s i n e s s c ar t a x a t i o n Electric vehicles The Government has set an objective that cost, the most attractive and efficient ULEVs, which have every new car or van registered in the UK the greatest zero-emission range, come out worst in this comparison. will be ultra-low emission by 2040, and zero- emission by 2050. Despite the recent surge in The Government could address this issue by altering the VED and BIK regimes so that there is more graduation for ultra-low emission vehicle registrations, which ULEVs, recognising both their average emissions and total saw 28,188 ULEVs added to UK roads in zero-emission range. 2015, there is a long way to go. The comparisons between Pure Electric vehicles, Plug-in Company fleets make rational purchasing decisions based Hybrid vehicles and traditional vehicles powered by an on detailed cost analysis – with Whole Life Costs being Internal Combustion Engine (ICE) are presented on the one of the key factors. Whole Life Costs take into account following pages. all the relevant costs for operating a vehicle over a certain period, including the acquisition cost, tax cost and running cost. Although the running costs of electric vehicles are lower than their petrol or diesel-powered counterparts, their higher up-front costs means that plug-in ULEVS often come out worse in a Whole Life Cost analysis with petrol or diesel - powered vehicles. In fact, due to their initial 11
Graphs 3a-3c: Whole Life cost comparisons – Pure electric, plug-in hybrid, and internal combustion engines – 10k miles per annum Graph 3a 2 years/20,000 miles £1,000.00 £900.00 £800.00 £700.00 Cost per month £600.00 £500.00 £400.00 £300.00 £200.00 £100.00 Graph£0.00 3a 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Electric Vehicle Plug-In Hybrid Vehicle Internal Combustion Engined Vehicle Graph 3b 3 years/30,000 miles £1,000.00 £900.00 £800.00 £700.00 Cost per month £600.00 £500.00 £400.00 £300.00 £200.00 £100.00 £0.00 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 12
B V R L A p o l i c y p a p e r – b u s i n e s s c ar t a x a t i o n Graph 3c 4 years/40,000 miles £1,000.00 £900.00 £800.00 £700.00 Cost per month £600.00 £500.00 £400.00 £300.00 £200.00 £100.00 £0.00 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 1 Peugeot ION 5DR Hatch 9 Volkswagen Golf 5DR Hatch 1.4 15 Volkswagen Golf 5DR hatch 1.6 TDI 2 Renault Zoe 5DR Hatch Expression Tsi 204 GTE DSG6 110 Match DSG7 Nav Auto Toyota AYGO 5DR Hatch 1.0 10 16 Audi A4 4DR Saloon 2.0 TDI Ultra 3 Nissan Leaf 5DR Hatch Visia 24KW VVT-1-X-Pure X-Nav X-Shift 150 SE S Tronic 4 BMW i3 5DR Hatch Edrive Auto 11 Volkswagen UP 5DR hatch 1.0 75 17 BMW 320d 4DR Saloon 2.0 Efficient 5 Tesla Model S 5DR hatch 70KWH High ASG Dynamics Plus Auto 6 Audi A3 5DR Sportback 1.4 FS1 204 12 Ford Fiesta 5DR Hatch 1.0T 100 18 Audi S5 2DR Coupe 3.0 TFS1 e-tron S Tronic Titanium Ecoboost Powershift Quattro 333 S Tronic Plus Auto 7 BMW i3 5DR Hatch EDrive Range 13 Vauxhall Corsa 5DR Hatch 1.4 19 BMW 535d 4DR Saloon 3.0 Extender Auto 90 SRI Auto M Sport Auto 8 Mitsubishi Outlander PHEV 5DR 2.0 14 BMW 116d 5DR Sporthatch 1.5 SE GX3H Auto Nav Auto Graph 3b reveals that for motorists driving 10,000 miles per annum, the vehicle with the longest range per charge - the Tesla Model S - is considerably more expensive across an average three-year lifespan than a hybrid, and still more expensive than most traditional ICE vehicles. Similarly, Graph 3a shows that over two years, the next best pure electric vehicle by range - the Renault Zoe - is around £100 less expensive per month compared to the Audi A3 hybrid. Furthermore, it is either more or equally expensive than around half the identified ICE cars across the same period. 13
Graph 4: Whole Life cost comparisons – Pure electric, plug-in vehicles, and internal combustion engines – 20k miles per annum Graph 4a 2 years/40,000 miles £1,200.00 £1,000.00 Cost per month £800.00 £600.00 £400.00 £200.00 £0.00 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Electric Vehicle Plug-In Hybrid Vehicle Internal Combustion Engined Vehicle Graph 4b 3 years/60,000 miles £1,200.00 £1,000.00 Cost per month £800.00 £600.00 £400.00 £200.00 £0.00 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 14
B V R L A p o l i c y p a p e r – b u s i n e s s c ar t a x a t i o n Graph 4c 4 years/80,000 miles £1,200.00 £1,000.00 Cost per month £800.00 £600.00 £400.00 £200.00 £0.00 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 1 Peugeot ION 5DR Hatch 9 Volkswagen Golf 5DR Hatch 1.4 15 Volkswagen Golf 5DR hatch 1.6 TDI 2 Renault Zoe 5DR Hatch Expression Tsi 204 GTE DSG6 110 Match DSG7 Nav Auto Toyota AYGO 5DR Hatch 1.0 10 16 Audi A4 4DR Saloon 2.0 TDI Ultra 3 Nissan Leaf 5DR Hatch Visia 24KW VVT-1-X-Pure X-Nav X-Shift 150 SE S Tronic 4 BMW i3 5DR Hatch Edrive Auto 11 Volkswagen UP 5DR hatch 1.0 75 17 BMW 320d 4DR Saloon 2.0 Efficient 5 Tesla Model S 5DR hatch 70KWH High ASG Dynamics Plus Auto 6 Audi A3 5DR Sportback 1.4 FS1 204 12 Ford Fiesta 5DR Hatch 1.0T 100 18 Audi S5 2DR Coupe 3.0 TFS1 e-tron S Tronic Titanium Ecoboost Powershift Quattro 333 S Tronic Plus Auto 7 BMW i3 5DR Hatch EDrive Range 13 Vauxhall Corsa 5DR Hatch 1.4 19 BMW 535d 4DR Saloon 3.0 Extender Auto 90 SRI Auto M Sport Auto 8 Mitsubishi Outlander PHEV 5DR 2.0 14 BMW 116d 5DR Sporthatch 1.5 SE GX3H Auto Nav Auto Graphs 4a, 4b and 4c all demonstrate that for drivers doing 20,000 miles per annum, the Tesla Model S costs considerably more than any hybrid and the majority of ICE vehicles - regardless of the lifespan. All other pure electric vehicles are cheaper than hybrid vehicles, and are comparable on a whole life cost basis to ICE vehicles - particularly over a four year lifespan. In order to ensure the greatest adoption of electric vehicles, HMRC should consider the introduction of a new tax category for EVs where these are taxed on the basis of the length of range – so for example, an EV with a 50 mile range would receive a higher BIK rating than one with a 70 mile range. In mirroring the three categories of the plug- in car grant, administered through the Office for Low Emission Vehicles (OLEV), this will both provide consistency and incentivise greater economy in EVs. Once again, in considering any changes to the tax system, any new taxation regime should be tax- neutral to maintain the take-up of EVs. 15
Salary sacrifice The BVRLA notes the reference to salary sacrifice arrangements in the 2016 Budget, that the Treasury will “actively monitor the growth and development of salary sacrifice schemes and their effect on tax receipts, and will look to consult on proposals to amend the legislation around these if the Treasury believe that these have an excessive cost to the taxpayer”. The BVRLA’s position is that as well as providing choice and flexibility for road users, salary sacrifice schemes provide a positive tax contribution to the Treasury, particularly through encouraging sales of new cars to be driven by employees in the lowest tax bracket (i.e. those who would be unlikely to purchase a new car otherwise). This position is summarised in the BVRLA’s response to the HM Treasury consultation on remuneration practices, in which the association included a case study based upon 2013 sales data provided by one BVRLA leasing member. This case study revealed the following results: „„ 84.3% of salary sacrifice arrangements were with employees in the 20% tax band, i.e. whose salaries were under £32,010; 14.6% in the 40% tax band; and the remaining 1.1% in the 45% tax band „„ The total estimated first year revenue to HMRC from direct taxation of salary sacrifice cars in 2013 was £3,370,710.79 and £11,695,742.23 across 36 months (the average length of a typical leasing arrangement) – this takes into account the total Vehicle Excise Duty, Company Car Tax, registration fees, employer Class 1A National Insurance Contributions 13 (NICs) and Value Added Tax across all salary sacrifice arrangements considered. „„ Based on the above figures, we calculate that the total average financial contribution to HMRC (through Vehicle Excise Duty, Company Car Tax, and Class 1A NICs and Value Added Tax, plus the original car registration fee in the first year) per salary sacrifice car will be £1,115.76 in the first year and £3,279.55 across the length of a typical 36-month salary sacrifice lease arrangement. 16
B V R L A p o l i c y p a p e r – b u s i n e s s c ar t a x a t i o n „„ In addition, the BVRLA calculates that the additional VAT from the disposal of the car at the end of the lease (taking an average residual value of 40% of a company car’s original P11D value) would equate to a further average VAT payment made to HMRC of £1,228.56 per salary sacrifice car. Taking this into account, the total average revenue to HMRC per salary sacrifice arrangement is £4,508.11. „„ As the BVRLA estimates that there are currently around 60,000 cars operated under salary sacrifice arrangements in the UK, this translates to an overall estimate of £270,486,600 received by HMRC in tax revenue from salary sacrifice company car arrangements. „„ Taking this case study as representative of the salary sacrifice market, if the figure of 84.3% of salary sacrifice company car schemes is made up by employees in the 20% tax band, the total estimated revenue to HMRC from salary sacrifice schemes by employees in the 20% tax band per 36-month cycle would be £229,913,610. The above figures amount to significant tax contributions to HMRC, the largest of which has come from salary sacrifice arrangements with employees in the lowest tax band. This is significant for three reasons – firstly, this reinforces the view that that overwhelming majority of employees taking a salary sacrifice car will not previously have had access to a brand new car. Secondly, the data suggests that abolishing or adding further taxation to such salary sacrifice arrangements would disproportionately impact the lowest paid (i.e. those in the 20% tax band). Finally, by extension, this would also suggest that these cars are unlikely to have been purchased by the leasing company in the absence of salary sacrifice schemes, since these employees are unlikely to have had the financial means to buy privately. For this reason, the last figure of £229,913,610 represents a combined tax contribution to HMRC which would unlikely have been made in the absence of salary sacrifice arrangements. The BVRLA therefore urges HM Treasury not to erode the availability of salary sacrifice arrangements on cars, given the benefits to employers, employees (especially those lower paid), and to HMRC. 17
Fuel duty The BVRLA believes that one of the strongest contributors to economic growth in both the rental and leasing sector and in other UK business sectors provided by the previous Government was the decision to freeze fuel duty in 2013. At a time when British businesses are still recovering from the global recession, we believe that fuel duty should remain frozen, which would provide both consistency and confidence to industry. We would welcome a commitment from the Chancellor in 2016 that fuel duty will remain frozen for the foreseeable future. 18
B V R L A p o l i c y p a p e r – b u s i n e s s c ar t a x a t i o n Summary of recommendations The BVRLA offers the Government the following recommendations in respect of business car taxation: „„ Carry out a wholesale review of the current system and levels of company car taxation, recognising the benefits of company cars in terms of reduced emissions and revenue to HM Treasury. „„ Abolish the 3% diesel supplement on benefit in kind tax bands for Euro 6C cars from 2016. „„ Reform the benefit-in-kind (BIK) ratings, with greater granularity on incentives for the take-up of lower emission vehicles. In particular, a wider differential at the lower category end is required to provide a larger incentive for the take up of lower (if not ultra-low) emission vehicles over slightly higher emission ones. „„ To reintroduce the balancing charge adjustment at the point of disposal of lease vehicles, for both the 18% general pool (vehicles emitting 110g/km of CO2 emission) and the 8% special pool (111g/km CO2 or above). By returning to the original system of lease operators receiving a single tax relief on disposal of lease vehicles, this would simplify the tax assessment for lease operators and restore fairness without sacrificing the financial incentive toward cleaner, greener vehicles. „„ Allow leased vehicles to be eligible for 100% First Year Capital Allowances. „„ Introduce a new tax category for electric vehicles (EVs) where these are taxed on the basis of the length of range (miles travelled before requiring a recharge). „„ Provide in-life incentives to ultra-low emission vehicles to grow confidence in the developing second-hand market. This is key in ensuring the roll-out of ULEVs, particularly EVs. „„ To not erode the benefits of company salary sacrifice arrangements. 19
Participating organisations The BVRLA would like to thank the following organisations for their participation in an open roundtable, as well as subsequent discussions: HM Treasury Clydesdale Bank Lex Autolease University of Buckingham GKL Car and Van Rental Society of Motor Business School Hitachi Capital Manufacturers and Traders Alphabet GB Ltd John Lewis Partnership Synergy Automotive Ltd Arval UK KPMG Tusker Direct Ltd Barclays Bank LeasePlan 20
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