The invoice carries one line: "panel van, rear seat and side window added". The dealer reads it as a roomier delivery vehicle, the tax authority reads the very same line as a different class of car, and neither reading has anything to do with the produce the vehicle will carry or the temperature it has to hold. When two vehicles running the same round end up in different cost brackets, the answer usually sits in the customs tariff position printed on that line, and in the handful of figures that put the vehicle there.
One chassis, two excise rates
In the version of List (II) annexed to the Special Consumption Tax Law that the Revenue Administration published after the amendment made by Law No. 7590 of 31/7/2026, goods vehicles sit under heading 87.04 and the Other line of that heading is taxed at 4%; semi-trailer tractors under 8701.20 and special purpose vehicles under 87.05 stay at the same 4%. The passenger car belongs to heading 87.03, where the Other ladder is built from engine capacity read together with the excise base: on an engine no larger than 1,400 cm³ the rate is 70% while that base stays under 650,000 TL and 80% in the band above 900,000 TL and up to 1,100,000 TL, and beyond 2,000 cm³ it climbs as far as 220%. A footnote to the same list adds that on 87.03 vehicles the tax computed at the ad valorem rate cannot fall below a minimum lump sum, set at 30,000 TL for (L) class vehicles and 100,000 TL for the rest. Because these rates move with each amending law, it pays to open the file in force before signing rather than to quote a figure from memory.
| Tariff heading and line | What puts a vehicle on it |
|---|---|
| 87.04 goods vehicles, Other line | being built to carry goods |
| 8701.20 semi-trailer tractors | being a tractor unit |
| 87.05 special purpose vehicles | being special purpose |
| 87.04, gross laden mass up to 4700 kg | a seat or side window beyond the driver's row |
| 87.04, closed body | carrying capacity below 620 kg |
| 87.03 goods-vehicle line | passenger capacity below half the carrying capacity |
| 87.03 passenger car, Other line | engine capacity and the excise base |
The figures that fix the rate sit on the registration document
The list never asks what the vehicle is called in the showroom; words like van, panel van or double cab carry no weight in its text. What it asks for is the maximum laden mass, the carrying capacity, the number of seating positions including the driver, the engine capacity and, on electric-only vehicles, the motor power. Most of that is printed on the registration document, and where the carrying capacity, which the list defines as the total load including driver and passengers that a vehicle can safely carry, has no line of its own, the gap between maximum laden mass and unladen weight gives you the same number. You will not find the side window and the closed body on the paper at all; both are visible on the vehicle itself, and both are the first thing that separates vehicles which look identical on file.
The goods-carriage line under heading 87.03 works not by a rate but by a test: on a vehicle used to carry goods whose maximum weight does not exceed 3.5 tonnes, the total number of seating positions including the driver is multiplied by 70 kg, and if the resulting passenger capacity stays below 50% of the carrying capacity, the vehicle falls into that line, with all-wheel-drive vehicles kept out of the test altogether. The rate is 15% both where the carrying capacity does not exceed 850 kg and the engine stays under 2,000 cm³, and where it exceeds 850 kg and the engine stays under 2,800 cm³; electric-only vehicles sit at 10%. Running the arithmetic on your own vehicle takes a minute: with a carrying capacity of 850 kg the half-way limit is 425 kg, three seating positions including the driver come to 210 kg, six come to 420 kg and the test still holds, while a seventh reaches 490 kg and drops the vehicle out of the line. Since the list counts fixed seat-mounting fittings as seats even when no seat is bolted on, taking the bench out again does not undo the sum.
This is also where a side-by-side comparison of two vehicles gives up. Inside heading 87.04 there is a separate line for closed-body vehicles whose carrying capacity falls below 620 kg, and the rate there is 10% with no seat at all behind the driver, so a small delivery van can miss the 4% purely because it cannot carry much. Carrying capacity is what remains once the body has been fitted, which means two vehicles built on one chassis part company on paper according to how heavy their boxes are. There is a further 15% line for vehicles with nine seating positions including the driver and an engine no larger than 3,200 cm³. In a zone where three separate lines can look at the same physical vehicle, putting two model names beside each other tells you nothing; what decides the matter is the heading under which the vehicle is declared. The question the list leaves unanswered sits right here too: a rate table says nothing about where a later conversion moves the registration, and that one belongs to your accountant.
The gap does not close on delivery day
Article 30(b) of Value Added Tax Law No. 3065 denies the deduction of the value added tax shown on the purchase documents of passenger cars belonging to a business, save for the cars that a business whose activity is wholly or partly the renting or operating of passenger cars uses for that very purpose; because the wording ties the exception to the cars used for that purpose, a distributor who happens to rent out one car cannot shelter the delivery vehicle under it. Article 24(b) of the same law then brings taxes, duties, charges and fund contributions into the taxable base, so the value added tax is computed on a price that already carries the excise. No deduction bar applies to vans, panel vans and lorries, so there the tax keeps circulating through the books, while on a passenger car it is calculated on an excise-inflated base and sticks to the acquisition cost.
Income Tax General Communiqué (Serial No: 332), published in the 5th Repeated Official Gazette No. 33124 of 31/12/2025, set the ceilings that apply in 2026: monthly rental expense on a passenger car stops at 46,000 TL, the excise and value added tax that may be written off as expense stops at 1,200,000 TL, and the depreciable base stops at 1,380,000 TL excluding excise and value added tax, or at 2,600,000 TL where those taxes were capitalised or the car was bought second hand. Renting instead of buying does not lift the ceiling, it only moves it: on the rental route the limit lands on the monthly expense, and no such cap reaches a commercial vehicle hired for the same work. Since the ceilings are reset by communiqué every year, a delivery car that falls into the passenger class carries the difference well past the excise line on day one and into every year of the ledger.
The cold side of the obligation never asks what the registration document says. Article 13(7) of the Food Hygiene Regulation requires that vehicles and/or containers used to carry food be capable, where necessary, of maintaining appropriate temperatures and of allowing those temperatures to be monitored, and the phrase and/or leaves both routes open: the temperature may be held by the body of the vehicle or by the container loaded into it. Change the character of the load and the neighbouring paragraphs of the same article come into play, since paragraph three calls for adequate separation whenever food travels alongside non-food goods or alongside different foods, and paragraph five calls for effective cleaning between loads, with disinfection where necessary, once a vehicle or container has carried anything else. What an inspection asks is whether the regime was held, whether it can be shown, and whether contamination was kept out.
The practical side of keeping the vehicle commercial and letting the box do the cooling is set out on our cold carriage in a standard vehicle page.
The arrangement has a formal name in the international literature as well. Clause 2.2.2 of WHO TRS 992, Annex 5, Supplement 12 describes temperature-modified transport as a category of its own: the cold comes from a passive system qualified with the product, while the body of the vehicle merely softens the outside temperature and so extends the autonomy of that passive packaging. The commercial vehicle that stays cheap on the tax side is precisely the vehicle this description calls for.
That turns the buying order upside down in a useful way: write down the daily volume and the temperature regime first, choose the box or container that will hold the load second, and only then look for a vehicle able to stay in the commercial class on paper with a carrying capacity that takes the load. Start from cabin comfort instead and the arithmetic does not end with the excise gap on purchase day, because the unrecoverable value added tax and the capped depreciation come back every year. Letting the box carry the cold is also what leaves the vehicle free to stay commercial.
