P46(car) - When & why are cars included?

Modified on Tue, 13 Aug at 4:38 PM

Background

Sending a P46(car) submission to HMRC can be performed at any time, and as often as necessary. When P46(car) reports were submitted on paper, HMRC recommended returns on a quarterly basis, that is no longer the case - the sooner you submit a P46(car) for an employee's car change, the sooner their tax code will be issued to reflect the change.

The Summary Report

The summary report that is generated when you prepare your submission should give you full information on what is about to be sent to HMRC, and why. There are four major events that may occur:

Event	Reason
Car Provided for the First Time	A car has been allocated to an employee (eg a new car), or when you are NOT replacing an existing allocation.
Car Withdrawn	A car has been 'ended' for an employee (they no longer have that vehicle) and it has NOT been replaced the next day.
Replacement Car	You have allocated a car to an employee that replaces a vehicle they already have. A replacement car can ONLY occur on the next day - if there is a gap of more than one day, it becomes two events (car withdraw, car provided). Please note that a Replacement Car is only possible via an electronic submission, and that the only notification sent to HMRC is of the newly allocated car.
Second/Additional Car	When an employee has two cars allocated AT THE SAME TIME

Cars Appearing on the List

The reasons for a car appearing on the list are shown in the right-hand column of the report, and there is a key to explain the various numbers/digits at the top. An example would be 3:A - which is a standard replacement car.

There are a number of events that can take place in the P11D Organiser that can trigger a car to appear on a P46(car) listing - please note that these are ONLY applicable to currently assigned cars - if a car has been replaced or withdrawn, then the only route for changes is via representation to HMRC (by employee, employer or both).

Reason	Explanation
Fuel Benefit has been Withdrawn	Relevant if you are removing fuel benefit from the employee at the end of the tax year (05/04). Please note that if you are withdrawing fuel benefit 'in year' you need to follow the guidance here.
Fuel Benefit has been Provided	Would generate a Replacement Car entry on the same start date as the original, but with the fuel benefit charged applied.
Change of list price (including factory fitted options)	Would generate a Replacement Car entry on the same start date as the original, but with the new list price.
Change of CO2	Would generate a Replacement Car entry on the same start date as the original, but with the new CO2 value.
Change of Range	Would generate a Replacement Car entry on the same start date as the original, but with the new Range.
Change of Private Use Contributions	Would generate a Replacement Car entry on the same start date as the original, but with the new payment value.
Change of Capital Contribution	Would generate a Replacement Car entry on the same start date as the original, but with the new capital contribution.

In the 2020/2021 tax year only, there are two other events that may have triggered a car appearing in the P46(car) submission.

Reason	Explanation
Range has been added	HMRC require a range for ULEVs from 2020/2021 - if there is a a ULEV in the fleet that has not got a range entered, the software will ask you to add the range, and then submit it to HMRC as a replacement car from 06/04/2020 to ensure correct tax coding is applied from that date. See here for more information about Range.
Electric Cars from a previous year	As there was such a dramatic change in the appropriate percentage of electric cars between 2019/2020 and 2020/2021 (16% >0%) the P11D Organiser can generate a replacement entry for these cars as from 06/04/2020 to ensure the correct tax coding is applied from that date. See here for more details.