EIM23210 - Car benefit: meaning of without any transfer of the property in it: part ownership

This page follows from EIM23205 in considering the meaning of “without any transfer of the property in it”.

Transfer of part ownership

It used to be argued that a transfer of part of the ownership in the vehicle avoided the car benefit charge, but this argument was quashed by the High Court in the case of Christensen (HMIT) v Vasili, 76TC116. If the other conditions are met, the car benefit charge is incurred whether or not the employee owns a part share in the car.

Effect of part ownership

The fact that an employee owns a share in a car is therefore insufficient to support an argument that car benefit cannot apply if the other conditions are all met.