Index
Why REBU documentation is more important than it seems
The purchase document: what it must include and why it is the key proof
Which expenses can reduce the REBU margin and how to document them
The sales invoice under REBU: how it should be drafted
The REBU registry book: what data needs to be recorded per transaction
What happens if the Tax Agency requests justification and the documentation is incomplete
Dealcar and integrated REBU documentation in each file
Frequently asked questions
Why REBU documentation is more important than it seems
REBU allows you to pay tax on the margin of each transaction instead of the full sale price. On a car bought for 15,000 euros and sold for 18,500, the difference between paying tax on the margin (3,500 euros) and on the full price (18,500 euros) can amount to several hundred euros of VAT per transaction.
This saving comes with one condition: that the Tax Agency can verify that the scheme has been applied correctly in each specific transaction. For this, it needs three things: proof that the vehicle was purchased from someone who could not pass on VAT, the expenses that reduced that margin, and the updated record of all transactions in the REBU book.
If any of these three elements is missing or incomplete, the Tax Agency can reject the application of the REBU to that transaction and liquidate the VAT on the full sale price. With a volume of 20 or 30 transactions per month, the impact of an inspection without documentation can be very significant.
Check the complete REBU guide for car dealerships.
The purchase document: what it must include and why it is the key proof
The purchase document is what proves that the vehicle was bought from someone who could not pass on VAT, which is the basic condition for being able to apply the REBU on resale.
When buying from a private individual, the purchase document can be a sales contract signed by both parties or a receipt signed by the seller. It must include the seller's full name and ID number, the vehicle's description (number plate, VIN, make and model), the date of the transaction and the purchase price. Without the seller's ID, the documentation is not sufficient to prove the origin to the Tax Agency.
When buying from another dealership that already applied the REBU to its sale, that dealership's invoice proves that the seller paid tax under that scheme. That invoice will not have itemised VAT (as the REBU does not allow it to be itemised) and must expressly state that the Special Scheme for Second-Hand Goods is applied.
When buying from a company or self-employed person who sold with itemised VAT on the invoice, that transaction cannot fall under the REBU. The proof of purchase in that case is an invoice with 21% VAT, which the dealership can deduct and which means that the resale must also be done with general VAT, not under the REBU.
Which expenses can reduce the REBU margin and how to document them
The REBU margin on which VAT is calculated is the difference between the sale price and the purchase price plus the expenses directly linked to the vehicle that the regulations allow to be deducted.
The expenses that reduce the REBU margin are the transport of the vehicle from the origin to the dealership and the repairs necessary to put the vehicle in a saleable condition. Both must be documented with an invoice from the corresponding supplier and clearly linked to the specific vehicle.
The expenses that do not reduce the REBU margin are the commercial warranty offered to the buyer (it goes separate from the price of the car on the invoice), general business expenses (rent, portals, payroll) and cosmetic preparation expenses that are not strictly repairs, although this last point may depend on interpretation and should be consulted with the tax advisor.
Using the specific example: a vehicle bought from a private individual for 15,496 euros, with 650 euros for transport and 332 euros of workshop costs to repair a mechanical problem detected during inspection. Sale price: 19,222 euros. REBU margin: 19,222 minus 15,496 minus 650 minus 332 = 2,744 euros. 21% VAT is applied to those 2,744 euros, not to the 19,222 euros of the sale price.
For these expenses to be deductible from the margin, they must be documented with invoices in the name of the dealership, with the vehicle reference (number plate or VIN) and with a date after the purchase and before the sale.
Read also REBU special cases: when it does not apply and how to manage negative margins.
The sales invoice under REBU: how it should be drafted
The invoice issued to the buyer under the REBU has specific characteristics that differentiate it from an invoice under the general VAT scheme.
It must not itemise the VAT. The price that appears on the invoice is the total price, which already includes the VAT calculated on the margin, but that VAT is not mentioned separately in either amount or percentage. The buyer cannot deduct that VAT because it is not itemised.
It must include an express mention of the applied scheme. The usual formula is "Special Scheme for Second-Hand Goods. VAT non-deductible by the recipient" or an equivalent indication in accordance with Article 138 of the VAT Regulations. Without this mention, the invoice may be considered incomplete in an inspection.
It must include the usual details of any invoice: invoice number, date, issuer's details (name, CIF, address), recipient's details (name or company name, NIF), description of the vehicle (number plate, VIN, make, model) and the total price.
Check which REBU invoicing program to use and what it must comply with.
The REBU registry book: what data needs to be recorded per transaction
The REBU registry book is the document that the Tax Agency reviews first when inspecting a dealership that applies this scheme. Its requirement is established in Article 138 of the VAT Regulations.
Read also what the REBU registry book must include and how to organise it.
For each REBU transaction, you must record: the purchase date of the vehicle, the sale date, the name and DNI or CIF of the supplier (the person or company from whom it was bought), the description of the vehicle (make, model, number plate and VIN), the purchase price, the expenses that reduce the margin with their amount, the sale price and the resulting margin.
The book must be updated transaction by transaction. If the Tax Agency detects that the records are not contemporary to the transactions (for example, that they were all made on the last day of the quarter), it may question their reliability and request additional documentation for each transaction.
At the end of each quarter, the sum of the positive margins in the registry book is the taxable base that goes into box 25 of form 303. Negative margins (transactions with losses) have a taxable base of zero and do not offset positive ones.
What happens if the Tax Agency requests justification and the documentation is incomplete
The Tax Agency can initiate a verification procedure for REBU transactions of the last four financial years. In this procedure, it can request the registry book, the purchase documents for each vehicle and the corresponding sales invoices.
If the registry book is incomplete, if the purchase document for any vehicle is missing or if there are inconsistencies between the book and the invoices issued, the Tax Agency can reject the application of the REBU to the affected transactions. In this case, it regularises the VAT, calculating it on the full sale price of those transactions, plus late payment interest from the corresponding period.
If the failure to comply is systematic, it can also lead to penalties for tax infringement, with amounts between 50% and 150% of the unpaid amount depending on the severity.
Check the most frequent REBU errors that generate problems with the Tax Agency.
The way to protect yourself is simple: document each transaction at the time it occurs, keep the purchase proofs with all the required data and keep the registry book updated. With a system that automates that registration, the additional work is minimal.
Dealcar and integrated REBU documentation in each file
Dealcar associates the purchase document, vehicle expenses and sales invoice with the file of each transaction. When the purchase of the vehicle is registered with its origin (private individual, another REBU, company), the system automatically applies the correct scheme and calculates the available margin.
The REBU registry book is updated with each transaction without additional work. At the end of the quarter, the totals are available for the agency without needing to reconstruct the information of the last few weeks.
If you want to see how it works, check out dealcar.io/facturacion-electronica-coches or request a free demo of dealcar.io.
Frequently asked questions
What purchase document does the Tax Agency accept to prove REBU origin?
A sales contract signed by the private seller with their name, ID, vehicle description, date and price. Also a signed receipt with those same details. What it does not accept is a bank transfer without an associated document or a verbal agreement without any written backing.
Can I apply the REBU if I buy the car from a company?
It depends on whether that company passed on VAT on the sale. If the purchase invoice has itemised VAT, the dealership deducted it and cannot apply the REBU on resale. If the company sold without VAT (due to being exempt or for other reasons), the REBU can be applied, but it must be properly justified.
Do cosmetic preparation expenses (cleaning, polishing) reduce the REBU margin?
The regulations allow repair and transport expenses to be deducted from the margin. Cosmetic preparation expenses are not strictly repairs and their deductibility from the REBU margin is debated. The most prudent stance is not to include them in the margin and to consult with your tax advisor if the amount is significant.
Can the REBU registry book be digital?
Yes. There is no mandatory official format. It can be a digital file, a spreadsheet or the record generated by management software, as long as it contains all the mandatory details per transaction and is available in the event of an inspection.
