Club vehicle - commercial van tax

christramp

Hi
I run a kayak club and I need to get a vehicle that can tow yet seat 5-7 people. I was using a diesel ford galaxy as a family car and used it to tow however it's now gone to car heaven. I've replaced the family vehicle but I need a horse to pull the trailer 1 or 2 evenings per week. With this minimal use I want to keep the tax and insurance as low as possible.
I work full time employed but also have a small kayak business that is registered but not for VAT.
I would ideally like to get a cheap crew cab van and run it on commercial tax, it would always have gear and boats in the back and I'd plan to get sign writing on the side.
I'm happy to bend a few rules however I am not blessed with luck so my option needs to be fairly robust.
I know the commercial tax Is a really vague area and my requirement may be impossible but I'd love to know if anyone can help me out with suggestions.
It's a shame I want to spend my money running a vehicle to help a club and be left with what seems a stupidly high tax rate option only.
Thanks in advance

Bpmull

If your buying the van and it's put in the businesses name I can't see a problem with taxing it commerically. Granted its easier to do if you have a vat number. But you should still be able to tax it commerically once the business name is on the log book.

corktina

the problem is the Feds are wise to crew cab vehicles and you will need to show you have a need to carry your 3/4/5 or so employees with you and what's more you will only be allowed use it for commercial use.

christramp

What way do most clubs run then - on private tax and Insurance, that can't be right surely. Would a mini bus or even a camper be better options ? Only thing there is it's a higher purchase price
Thanks for the comments so far :-)
Thanks

wexie

corktina wrote: »

the problem is the Feds are wise to crew cab vehicles and you will need to show you have a need to carry your 3/4/5 or so employees with you and what's more you will only be allowed use it for commercial use.

Not sure it would have to be employees no?

If OP could prove that the truck is being used to transport paying customers, their gear and some kayaks surely that would suffice?

Especially if you have a private vehicle I don't think there should be any problem with doing this.

Cleveland Hot Pocket

christramp wrote: »

What way do most clubs run then - on private tax and Insurance, that can't be right surely. Would a mini bus or even a camper be better options ? Only thing there is it's a higher purchase price
Thanks for the comments so far :-)
Thanks

On private insurance you would not be covered for any commercial use though.

christramp

I want this for a club - I would only I nvolve the business if it was a means to an end - I have no actual use for the vehicle for the business.
Thanks for the comments

Cleveland Hot Pocket

christramp wrote: »

I want this for a club - I would only I nvolve the business if it was a means to an end - I have no actual use for the vehicle for the business.
Thanks for the comments

I would say that the best option is get a commercial policy that also covers SD&P (most offer this option) and commercial tax.
Register the van to the company and then off ya go.

corktina

wexie wrote: »

Not sure it would have to be employees no?

If OP could prove that the truck is being used to transport paying customers, their gear and some kayaks surely that would suffice?

Especially if you have a private vehicle I don't think there should be any problem with doing this.

taxi license required I guess...

has to be employees or some other work related use that I can't guess at

corktina

Cleveland Hot Pocket wrote: »

I would say that the best option is get a commercial policy that also covers SD&P (most offer this option) and commercial tax.
Register the van to the company and then off ya go.

still not allowed to use it privately if it's commercial taxed.

corktina

christramp wrote: »

What way do most clubs run then - on private tax and Insurance, that can't be right surely. Would a mini bus or even a camper be better options ? Only thing there is it's a higher purchase price
Thanks for the comments so far :-)
Thanks

Camper would be a great option, comes complete with facilities for the weekend and well able to pull a trailer.....buy mine and you get Classic Insurance too as well as cheap tax....it's on adverts.ie

Cleveland Hot Pocket

corktina wrote: »

still not allowed to use it privately if it's commercial taxed.

I think that you will find you can.
Just because the tax office tells you something doesn't mean it is true

corktina

you can but not legally. A commercially taxed vehicle can only be used commercially. No private use allwed and you have to sign a declaration to that effect.

Cleveland Hot Pocket

corktina wrote: »

you can but not legally. A commercially taxed vehicle can only be used commercially. No private use allwed and you have to sign a declaration to that effect.

If you sign the declaration, then yes you are doing so illegally. Your illegal action is breaking the declaration that you signed, and your misrepresentation of your vehicle use to the county council.

However if we look strictly at the definition of commercial tax, there is no requirement that the taxed vehicle be "solely" used for commercial reasons. There is no legal basis to state that a commercial vehicle, owned by a business and used commercially, cannot be used privately also, provided it is insured for both commercial and SDP.

If I am wrong, please provide an SI that specifically outlaws a commercially taxed vehicle being used a minority of the time for SDP purposes and I will accept that I am wrong

corktina

the declaration is fairly recent but it has always been the case that commercially taxed vehciles cannot be used for anything but commercial activities (not that it ever stopped anyone doing it, me included.

R.O.R

Cleveland Hot Pocket wrote: »

If you sign the declaration, then yes you are doing so illegally. Your illegal action is breaking the declaration that you signed, and your misrepresentation of your vehicle use to the county council.

However if we look strictly at the definition of commercial tax, there is no requirement that the taxed vehicle be "solely" used for commercial reasons. There is no legal basis to state that a commercial vehicle, owned by a business and used commercially, cannot be used privately also, provided it is insured for both commercial and SDP.

If I am wrong, please provide an SI that specifically outlaws a commercially taxed vehicle being used a minority of the time for SDP purposes and I will accept that I am wrong

And how do you propose taxing a commercial vehicle, commerically, allowing for private usage, and not falsely declaring you'll only use it for carrying goods?

We have to get Goods Only Declarations signed for all commercial vehicles, before we tax them for the first time. All are registered in the name of our VAT registered company.


We did get a Crew Cab van taxed as a commercial today, but had to submit a Goods Declaration. Will be used mainly for carrying equipment from one site to another, and occasionally carrying personel from one site to another.

Motortax.ie had it in that it would need to be taxed on engine size.

Cleveland Hot Pocket

corktina wrote: »

the declaration is fairly recent but it has always been the case that commercially taxed vehciles cannot be used for anything but commercial activities (not that it ever stopped anyone doing it, me included.

Please provide a current SI to back up this viewpoint, it has no basis in current legislation

The law is not "anything but" commercial activities.

The only illegal act is falsely signing the declaration.

R.O.R

Cleveland Hot Pocket wrote: »

Please provide a current SI to back up this viewpoint, it has no basis in current legislation

The law is not "anything but" commercial activities.

The only illegal act is falsely signing the declaration.

Does this count?

Letter from 2005 to tax offices wrote:

The legal basis for taxing goods vehicles is provided in paragraph 5 of Part 1 of the Schedule to the Finance (Excise Duties)(Vehicles) Act 1952 as inserted by section 3 of the Motor Vehicle (Duties and Licences) Act 2004. Every time there is a change in motor tax rates there is a new Act which inserts a new Schedule of rates into the 1952 Act. Paragraph 5 provides:

“5. Vehicles (including tricycles weighing more than 500 kilograms unladen) constructed or adapted for use and used for the conveyance of goods or burden of any other description in the course of trade or business (including agriculture and the performance by a local or public authority of its functions) and vehicles constructed or adapted for use and used for the conveyance of a machine, workshop, contrivance or implement by or in which goods being conveyed by such vehicles are processed or manufactured while the vehicles are in motion.

The purpose of the wording in italics/underlined is to include cement mixers in this tax class.

Most vehicles can in some fashion convey goods or burden but to be taxed as a goods vehicle the vehicle must be constructed or adapted for that purpose. This construction requirement to carry goods applies equally to a constructed or adapted vehicle and, accordingly, an adapted vehicle must have the same characteristics of a goods vehicle in relation to space and accommodation for carrying goods and limited seating capacity. This means that applications to tax an adapted vehicle at the goods rate must satisfy the following conditions:

(A) The goods carrying area to be greater than the seating area, and

(B) All seats to the rear of the driver’s seat to be removed and seat bolt holes welded over, and

(C) All rear seat belts removed and seat belt anchor points welded over.

It is not necessary to blacken side windows.

It is essential that all motor tax offices follow these guidelines.

I'm sure the actual, published SI exists somewhere, but there are so many amendements coming up, that I don't have the time to find them.

Cleveland Hot Pocket

That doesn't count, it is a letter to tax offices.

Motor tax offices are not above the law, despite what they may like to think


Also, it doesnt even say anything about use:

to be taxed as a goods vehicle the vehicle must be constructed or adapted for that purpose

Here it refers somewhat to useage alright, but no mention of sole commercial use

Vehicles (including tricycles weighing more than 500 kilograms unladen) constructed or adapted for use and used for the conveyance of goods or burden of any other description in the course of trade or business

corktina

"I declare that vehicle registration number will be used only as a goods carrying vehicle in the course of my business/trade and will not be used at any time for social, domestic or pleasure purposes."

That's the wording from the RF111a...quite clear. (relevant bit is even in bold.

christramp

Hmmm - Its great to see a discussion and there are a lot of opinions but typically for Ireland there is no clear cut answer. Im going to have to see about a small engine 4x4 that can tow a heavy trailer as I know my luck with a crew cab van ill get caught (Guaranteed) - the cheaper end of campers are battered and seeing as all I want to do is tow a club trailer once or twice a week I don't want to spend a lot on purchase or tax - I really thought there would have been an option for sports clubs - I can show registration and insurance but it wont make any difference I suppose.
Thanks guys for all the thoughts & opinions

corktina

if its a heavy trailer you may need a BE license to haul a trailer.

It does surprise me that you have the dosh to buy a 4x4 to use occasionally but aren't wanting to pay your dues in taxes on it like most of us do. Seems to me you should buy get rid of the family car and buy a 4x4 that will do both jobs for you and tax it privately

Cleveland Hot Pocket

corktina wrote: »

"I declare that vehicle registration number will be used only as a goods carrying vehicle in the course of my business/trade and will not be used at any time for social, domestic or pleasure purposes."

That's the wording from the RF111a...quite clear. (relevant bit is even in bold.

Yes, that is a declaration.
However if you are not asked to sign the declaration then there is nothing illegal.

Also, if you sign the declaration you are guilty only of making false representation, not of tax evasion. There is nothing illegal about using a vehicle taxed commercially for private use too.

I have asked for legislation that renders it illegal, but as yet there is none

R.O.R

Cleveland Hot Pocket wrote: »

Yes, that is a declaration.
However if you are not asked to sign the declaration then there is nothing illegal.

Also, if you sign the declaration you are guilty only of making false representation, not of tax evasion. There is nothing illegal about using a vehicle taxed commercially for private use too.

I have asked for legislation that renders it illegal, but as yet there is none

The Finance (excise duties)(vehicles) Act, 1952 states:

5. Vehicles (including tricycles weighing more than 500 kilograms unladen) constructed or adapted for use and used for the conveyance of goods or burden of any other description in the course of trade or business (including agriculture and the performance by a local or public authority of its functions) and vehicles constructed or adapted for use and used for the conveyance of a machine, workshop, contrivance or implement by or in which goods being conveyed by such vehicles are processed or manufactured while the vehicles are in motion:


Notice is states for the conveyance of goods. Not the "predominant" conveyance of goods. Not the conveyance of goods, and occasionally dropping the kids to school, or doing the weekly shopping, or whatever you fancy, as long as it's mostly conveying goods.

Read it how you will, may have been better if it stated "only" for the conveyance of goods etc.

Just because it doesn't say that no private usage is allowed, doesn't mean that private usage is allowed.

Being responsible for the correct taxation of thousands of vehicles (including hundred's of "commercial" vehicles), I'm quite aware of the workings of the motor tax offices

Cleveland Hot Pocket

R.O.R wrote: »

The Finance (excise duties)(vehicles) Act, 1952 states:

5. Vehicles (including tricycles weighing more than 500 kilograms unladen) constructed or adapted for use and used for the conveyance of goods or burden of any other description in the course of trade or business (including agriculture and the performance by a local or public authority of its functions) and vehicles constructed or adapted for use and used for the conveyance of a machine, workshop, contrivance or implement by or in which goods being conveyed by such vehicles are processed or manufactured while the vehicles are in motion:


Notice is states for the conveyance of goods. Not the "predominant" conveyance of goods. Not the conveyance of goods, and occasionally dropping the kids to school, or doing the weekly shopping, or whatever you fancy, as long as it's mostly conveying goods.

Read it how you will, may have been better if it stated "only" for the conveyance of goods etc.

Just because it doesn't say that no private usage is allowed, doesn't mean that private usage is allowed.

Being responsible for the correct taxation of thousands of vehicles (including hundred's of "commercial" vehicles), I'm quite aware of the workings of the motor tax offices

Used for the conveyance of goods, which it would be.
No mention of "solely"

I have answered this one already earlier in thread.

Any actual legislation that states solely for commercial use at all? No?
(BTW the "workings of the tax office" do not always equate to law )

R.O.R

Cleveland Hot Pocket wrote: »

Used for the conveyance of goods, which it would be.

When a commercial vehicle is being used for dropping the kids to school, is it being used for the conveyance of goods?

Cleveland Hot Pocket

R.O.R wrote: »

When a commercial vehicle is being used for dropping the kids to school, is it being used for the conveyance of goods?

No but the vehicle is taxed at the goods rate because the vehicle is also used for goods transport.
Again, and this is the third time at least that I have said this now, there is no reference to sole commercial use in the act.

There is reference to a vehicle "being used for the conveyance of goods", which as a commercial vehicle it is used for that purpose. Just not 100% of the time and there is no law that contradicts this.


If a taxi (with PSV tax) is used by the taximan for driving home after work and he stops for a coffee, is that not allowed either? Some of the misinformation on this topic is dangerous. Not having a go at you in particular ROR, just saying that it is not clear 100% either way in a simple definitive manner (and even if it were, it would not be enforced properly either, such is the country we live in)

christramp

"if its a heavy trailer you may need a BE license to haul a trailer.

It does surprise me that you have the dosh to buy a 4x4 to use occasionally but aren't wanting to pay your dues in taxes on it like most of us do. Seems to me you should buy get rid of the family car and buy a 4x4 that will do both jobs for you and tax it privately"

Thanks - I have a UK licence that covers me for towing heavy trailers and I have no intention of changing it until it expires
The family car is an efficient low tax 1.6 diesel - I travel 1400 kms to work each week so a 4x4 is certainly not practical

In regards to me having the "dosh" to buy a vehicle and use it occasionally well that's my business but it's being paid for by my hard worked and heavily taxed income
Finally " aren't wanting to pay your dues in taxes on it like most of us" - at what point did I say I was not wanting to pay my dues ? I pay all road and income tax ! - my question is about an affordable option for running a club vehicle - paying nearly 700 a year tax on a 1.9 diesel for maybe 40 uses a year does not sit well with me. Plus I need a vehicle that can take bashes and I don't need to worry about it being kept clean :-)

Does anyone know if it's possible to register and run a vehicle as a club? Would if sit as private or commercial if it was possible

R.O.R

Cleveland Hot Pocket wrote: »

No but the vehicle is taxed at the goods rate because the vehicle is also used for goods transport.
Again, and this is the third time at least that I have said this now, there is no reference to sole commercial use in the act.

There is reference to a vehicle "being used for the conveyance of goods", which as a commercial vehicle it is used for that purpose. Just not 100% of the time and there is no law that contradicts this.

Nor is there any law which states that usage of a goods vehicle for private usage, is allowable when it's taxed as a goods vehicle. Or can you show otherwise?

Having had a lengthy conversation with a fleet manager, of a large commercial fleet, who spent a day in court because one of his vans was caught on the school run, with commerical tax, I'll use my interpretation of the law rather than yours.

Cleveland Hot Pocket

R.O.R wrote: »

Nor is there any law which states that usage of a goods vehicle for private usage, is allowable when it's taxed as a goods vehicle. Or can you show otherwise?

Having had a lengthy conversation with a fleet manager, of a large commercial fleet, who spent a day in court because one of his vans was caught on the school run, with commerical tax, I'll use my interpretation of the law rather than yours.

By virtue of the fact there is no law against it.
If this is true, then can I buy a truck that is due for commercial tax at €5k per year, but tax it at the private CC rate because I will only use it for SDP?

Oh yeah, and I notice the lack of citation of actual laws prohibiting it, just "a friend of a man on the internet"

R.O.R

Cleveland Hot Pocket wrote: »

By virtue of the fact there is no law against it.
If this is true, then can I buy a truck that is due for commercial tax at €5k per year, but tax it at the private CC rate because I will only use it for SDP?

Fcuked if I know - why don't you give it a go.

Cleveland Hot Pocket wrote: »

Oh yeah, and I notice the lack of citation of actual laws prohibiting it, just "a friend of a man on the internet"

I've cited the Finance Act 1952. What have you got to back it up? You have 1 car and 1 commercial. I have a little more experience..........;)

Cleveland Hot Pocket

R.O.R wrote: »

Fcuked if I know - why don't you give it a go.



I've cited the Finance Act 1952. What have you got to back it up? You have 1 car and 1 commercial. I have a little more experience..........;)

The finance act which is as clear as mud on the topic to be fair.

And then, when all else fails including the "I heard from a man at the bar" or equivalent, try the "I'm bigger than you" line.

Doesn't wash here I am afraid. I'll take my chances. Given that the AGS here couldn't catch a cold when it comes to non speeding offences, even if I am wrong it is very unlikely to have repercussions anyway.

R.O.R

Cleveland Hot Pocket wrote: »

The finance act which is as clear as mud on the topic to be fair.

And then, when all else fails including the "I heard from a man at the bar" or equivalent, try the "I'm bigger than you" line.

Doesn't wash here I am afraid. I'll take my chances. Given that the AGS here couldn't catch a cold when it comes to non speeding offences, even if I am wrong it is very unlikely to have repercussions anyway.

Still no citation of an SI or act to back up your claims?

Cleveland Hot Pocket

R.O.R wrote: »

Fcuked if I know - why don't you give it a go.

The reason you can't is because it is a commercial vehicle designed and used for the conveyance of goods as it's primary function.

See the correlation?

Cleveland Hot Pocket

R.O.R wrote: »

Still no citation of an SI or act to back up your claims?

Really?
As we both know the SI already quoted does not state what you claim, so there is no need to cite anything further.

I have already cited that act in my point earlier. It states what I am saying, that a vehicle must be designed and used for the conveyance of goods. Both of which criteria a commercial vehicle used by a company would meet.

At no point does it say the above criteria must be met to the exclusion of all other.

Markcheese

R.O.R wrote: »

When a commercial vehicle is being used for dropping the kids to school, is it being used for the conveyance of goods?

I've loads of work crap in the back of my van which I convey to school and back at school times,(which coincides with picking up kids)

TrailerBob

christramp wrote: »

"

Does anyone know if it's possible to register and run a vehicle as a club? Would if sit as private or commercial if it was possible

To get to your actual question.... I had this very problem in February with my amateur theatre group. We bought an iveco van for carrying sets and props, but ended up having to tax it privately.. We're not vat registered and The tax office would accept nothing else. Their advice was to register under the Charities Act for community involvement.. They get commercial tax rates.

We have since sold the van

christramp

To confuse matters even more I just called a neighbouring county's tax office who confirmed I can run and tax a crew cab van as commercial as long as there is no Sd&P use - which for me is spot on however they said I cannot tax the vehicle with them as I am in another county.
I phoned my county tax office who could not tell me if I can run a club vehicle on commercial tax yet without knowing the facts themselves they adamantly shut me down with an affirmative no when I mentioned a crew cab.
When two councils are polar opposites then how the hell are the rest of us supposed to figure it out.
I'm gonna pop into my local guard station later in the week and see if they can help as if anyone is gonna stop me on the road it's gonna be them :-(

Cleveland Hot Pocket

christramp wrote: »

To confuse matters even more I just called a neighbouring county's tax office who confirmed I can run and tax a crew cab van as commercial as long as there is no Sd&P use - which for me is spot on however they said I cannot tax the vehicle with them as I am in another county.
I phoned my county tax office who could not tell me if I can run a club vehicle on commercial tax yet without knowing the facts themselves they adamantly shut me down with an affirmative no when I mentioned a crew cab.
When two councils are polar opposites then how the hell are the rest of us supposed to figure it out.
I'm gonna pop into my local guard station later in the week and see if they can help as if anyone is gonna stop me on the road it's gonna be them :-(

This is the problem.
There is a crying out need for a clear law here.
The current law is ambiguous at best, given myself and ROR's directly opposing interpretations of the same act and wording.

Councils and tax offices are not laws onto themselves, much as the civil servants there like to think they are at times.

*cough* tax on fuel would be so much easier to enforce than all of this *cough*

corktina

R.O.R wrote: »

Nor is there any law which states that usage of a goods vehicle for private usage, is allowable when it's taxed as a goods vehicle. Or can you show otherwise?

Having had a lengthy conversation with a fleet manager, of a large commercial fleet, who spent a day in court because one of his vans was caught on the school run, with commerical tax, I'll use my interpretation of the law rather than yours.

clues in the name...commercial tax is for commercial purposes....however it can be interpreted, it HAS been interpreted as goods use only on the declaration form and you can't tax a new (to you) vehicle without making the declaration so it's a fait accompli really.

Cleveland Hot Pocket

corktina wrote: »

clues in the name...commercial tax is for commercial purposes....however it can be interpreted, it HAS been interpreted as goods use only on the declaration form and you can't tax a new (to you) vehicle without making the declaration so it's a fait accompli really.

This is the issue, motor tax offices making laws

corktina

no, if you take the 1932 wording literally, then Commercial Tax is for Commercial Vehicles literally. That your interpretation is different is hardly of relevance.

Cleveland Hot Pocket

corktina wrote: »

no, if you take the 1932 wording literally, then Commercial Tax is for Commercial Vehicles literally. That your interpretation is different is hardly of relevance.

Firstly, it is not my interpretation, it is the interpretation that has been in place for years until a green minister thought otherwise.

Secondly, link please. A search on the statute book website doesn't really link anything.

christramp

Thanks for the comments and debate guys. I've spoken again to the council and they are now adamant that in no way can a club get commercial tax and we are certainly not going to pay the private tax rate for the use it's going to get.
My only option now is to start looking for a converted camper van derived from a large panel van that is registered on the log book as a camper. Going to be a tough look as it will need 5 seat belts but it's all I have left to go for tbh.
Thanks again guys

trad

There's a class of motor tax for "Youth or Community Bus" https://www.motortax.ie/OMT/motortaxinfotype.do

Your club may well qualify for this. The rate for 0 to 20 seats is €154 p/a. THe 0 to 20 would suggest that the vehicle does not have to be a minibus (9+ seats).

R.O.R

trad wrote: »

There's a class of motor tax for "Youth or Community Bus" https://www.motortax.ie/OMT/motortaxinfotype.do

Your club may well qualify for this. The rate for 0 to 20 seats is €154 p/a. THe 0 to 20 would suggest that the vehicle does not have to be a minibus (9+ seats).

Unfortunately, it does have to be a minibus - info on the motortax site is a little mis-leading.

To tax a vehicle as a Youth or Community Bus, it needs to have a valid DOE test (or whatever it's now called). DOE centre's won't test anything with less than 10 seats (driver + 9).

We did have a 9 Seat Tourneo that was taxed for the 1st year as a Charity bus (on lease to a Charity organisation) - supplying dealer organised that with their local tax office. Issues arose when we sent it for the required DOE after the 1st year, and they wouldn't look at it. Had to get the tax class changed to private at €1,050 for the year.

Think the OP said he has a UK Licence, so may well be licenced for up to 15 seats. Whether a Kayak club qualifies as usage for the community is another matter.........

corktina

Cleveland Hot Pocket wrote: »

Firstly, it is not my interpretation, it is the interpretation that has been in place for years until a green minister thought otherwise.

Secondly, link please. A search on the statute book website doesn't really link anything.

no the interpretation has always been (long prior to the Greens) that you cannot legally use a commercial for private purposes...that we all ignored it is by the by

Cleveland Hot Pocket

corktina wrote: »

no the interpretation has always been (long prior to the Greens) that you cannot legally use a commercial for private purposes...that we all ignored it is by the by

You are not even making sense now.
If it was not the interpretation, then how do we have the option to "ignore" it.
Do we have the option to ignore other laws? Who decides what we can ignore?

corktina

It is you not making sense! There is no option to ignore the law, no one decides that we can...we just did! That someone breaks a Law doesn't mean that that Law ceases to be!

Cleveland Hot Pocket

corktina wrote: »

It is you not making sense! There is no option to ignore the law, no one decides that we can...we just did! That someone breaks a Law doesn't mean that that Law ceases to be!

But if the law was never enforced (assuming for the minute that I am wrong with my interpretation and the new one is correct), who decided that it was irrelevant in the first place?

AGS never enforced it, the motor tax offices didn't either.

corktina

It was enforced but not wholeheartedly.
Noone decided it was irrelevant.
AGS often did enforce it, it's why they tend to ask if you are on your way home from work?(if you say NO, I'M OFF TO THE PUB they might say why are you driving a commercial for non-commercial purposes.

Look at it this way: SDP tax costs x amount....Commercial tax is cheaper....why would commercial tax including SDP be cheaper than SDP on it's own? It's obvious that the interpretation that Commercial Tax is just for Commercial use is correct .The clue is in the name!