🇬🇧 EN
🇬🇧 EN

REBU y casos especiales: IVA reducido, movilidad reducida y situaciones que generan dudas

Smiling young man with light hair, black and white photo.

Carlos Horno

4

min read

Portada artículo "REBU y casos especiales: IVA reducido, movilidad reducida y situaciones que generan dudas"

REBU y casos especiales: IVA reducido, movilidad reducida y situaciones que generan dudas

Smiling young man with light hair, black and white photo.

Carlos Horno

4

min read

Portada artículo "REBU y casos especiales: IVA reducido, movilidad reducida y situaciones que generan dudas"

Index

  1. Quick recap: how the REBU works in the standard case

  2. How the REBU margin is calculated: formula and complete example

  3. Which expenses reduce the REBU margin and which do not

  4. The 4% VAT for reduced mobility: who can apply it and how

  5. When the REBU does not apply and general VAT must be used

  6. Purchases from companies and sole traders: normal VAT even if the car is used

  7. Cars with an invoice without VAT: what it means and when it happens

  8. Negative margin in REBU: what happens and how it is managed

  9. Exports under REBU: the specific rules

  10. REBU and Verifactu: how they relate

  11. Frequent mistakes that cause problems with the Tax Agency

  12. Dealcar and the tax control of transactions

  13. Frequently Asked Questions


Quick recap: how the REBU works in the standard case

The REBU (Special Scheme for Used Goods) is an optional VAT scheme that allows second-hand car dealerships to pay tax on the margin of the transaction instead of the total sale price. Under the general scheme, VAT is applied to the full sale price. Under the REBU, it is only applied to the difference between the sale price and the purchase price.

See the complete REBU guide for car dealerships for the standard case before reading the special cases.

The condition for applying the REBU is that the vehicle must have been acquired from someone who could not pass on VAT on the sale: a private individual, a dealership that already sold it under REBU, a company exempt from VAT, or a taxable person who acquired the asset for their own use.

The REBU VAT is not broken down on the invoice: the price that appears on the invoice to the buyer already includes the VAT on the margin, with no separate mention. This means that the buyer cannot deduct that VAT even if they are a business, and that the invoice issued under REBU does not generate break-downable output VAT.

How the REBU margin is calculated: formula and complete example

The REBU margin is the taxable base on which VAT is calculated. The formula is:

REBU Margin = Sale price − Purchase price − Deductible expenses

The VAT to be settled is: REBU Margin × 21% / 121

That division by 121 (and not multiplying directly by 21%) is because the sale price already includes the VAT on the margin. The VAT is inside the price, it is not added on top.

Read also what the REBU registry book must include and how to organize it.

Complete example with real numbers:

A dealership buys a Toyota RAV4 from a private individual for 14,500 euros. It pays 320 euros for transport from the seller's home and 480 euros for a workshop to repair the brakes and change the tyres. They sell it to a final buyer for 18,200 euros.

Margin calculation:

  • Sale price: €18,200

  • Purchase price: €14,500

  • Transport: €320

  • Repair: €480

  • REBU Margin: 18,200 − 14,500 − 320 − 480 = €2,900

VAT to be settled: 2,900 × 21 / 121 = €503.31

If the dealership had paid tax under the general scheme on the full sale price: 18,200 × 21% = 3,822 euros in VAT. The difference is more than 3,300 euros for this single transaction, which is the real saving that the REBU generates when applied correctly.

This margin of 2,900 euros is the figure recorded in the REBU registry book and added to the margins of the other transactions for the quarter to calculate box 25 of form 303.

See also the Verifactu landing page for Dealcar dealerships.

Which expenses reduce the REBU margin and which do not

This is the question that generates the most confusion in daily practice. Not all expenses associated with a vehicle reduce the REBU margin, and putting in expenses that do not apply is an error that the Tax Agency can detect in an inspection.

Expenses that DO reduce the REBU margin:

The transport of the vehicle from the point of purchase to the dealership or to the final customer is expressly recognized as a deductible expense of the REBU margin. It must be documented with an invoice from the carrier that includes the vehicle reference (registration plate or VIN).

The repairs necessary to put the vehicle in saleable condition also reduce the margin. These are the mechanical or bodywork jobs that the car needs before it can be sold: brake changes, tyre replacement, bodywork repair, replacement of defective parts. They must be documented with an invoice from the workshop with the vehicle reference.

Expenses that DO NOT reduce the REBU margin:

The commercial warranty offered to the buyer does not reduce the REBU margin even if it is included in the sale price. If the warranty is invoiced separately, it is taxed at the general rate of 21% as an independent service.

General business expenses (rent of the premises, listing portals, management tools, staff payroll, business insurance) are structural expenses that are not attributable to a specific vehicle and do not reduce the REBU margin. They are deducted as business expenses in the personal income tax (IRPF) or Corporate Tax, but not in the calculation of the REBU margin.

Aesthetic preparation expenses (cleaning, polishing, interior detailing) are in a grey area: the VAT Law only expressly mentions transport and repairs as deductible expenses of the margin. Pure aesthetic expenses are not repairs and their deductibility is not clearly recognized. The most prudent stance is not to include them in the margin and to consult with your tax advisor if the amount is significant.

The agency fees for the transfer also do not reduce the REBU margin. It is a business cost that is tax-deducted in another way.

Summary table:

Expense

Does it reduce the REBU margin?

Vehicle transport

Yes

Mechanical repairs

Yes

Bodywork repair

Yes

Commercial warranty

No

Aesthetic preparation expenses

No (grey area)

Portals and advertising

No

Transfer agency fees

No

Rent of the premises

No


The 4% VAT for reduced mobility: who can apply it and how

The reduced VAT rate of 4% for vehicles intended for people with reduced mobility is one of the special cases that generates the most confusion. It is regulated in Article 91 of the VAT Law and in Royal Decree 1576/2006.

For the 4% rate to be applied, three conditions must be met simultaneously. The first is that the buyer must be a person with a recognized disability with a degree equal to or greater than 33% in the case of physical disabilities, or equal to or greater than 65% in the case of mental or sensory disabilities. The second is that the vehicle will be used exclusively or mainly by that person. The third is that the vehicle does not exceed the established limits regarding engine capacity and type: currently, it applies to passenger cars and other motor vehicles up to 2,000 cc in the case of petrol and up to 2,500 cc in the case of diesel.

The application process requires the buyer to provide the dealership with the supporting documentation: the certificate of disability issued by IMSERSO or by the corresponding autonomous community and a solemn declaration indicating that the vehicle will be used for their personal use. The dealership must keep this documentation as proof of the application of the reduced rate.

See also which financial company to choose for customers with special needs.

A key point that generates confusion: the 4% rate applies to VAT, not to the REBU. If the vehicle is purchased under REBU, the REBU does not contemplate reduced rates: the margin is always taxed at the general rate of 21%. The 4% VAT is only applicable in transactions with broken-down VAT, i.e., when the transaction is not done under REBU but with normal VAT on the sale price.

In practice, this means that to apply the 4% VAT to a buyer with reduced mobility, the dealership has to sell the car with normal VAT (not under REBU), which implies that they must have purchased the vehicle with an invoice showing broken-down VAT. If the dealership bought the car from a private individual (without VAT) and intends to sell it with 4%, they cannot: they have no input VAT to offset and the REBU does not allow reduced rates.

Cuándo el REBU no aplica y hay que usar IVA general

The REBU is not applicable in all cases. There are situations in which the dealership must use the general VAT scheme even if the vehicle is second-hand.

The most frequent is the purchase of a vehicle from a company or sole trader who sold it with broken-down VAT on their invoice. If the seller charged VAT on the transaction, the buyer (the dealership) deducted that VAT. When reselling the vehicle, they must charge VAT at the general rate because they already benefited from the deduction upon purchase.

Another situation is the import of vehicles from countries outside the EU, where the vehicle has paid import VAT at customs upon entering Spain. That VAT is deductible for the dealership, which must charge normal VAT when reselling the vehicle.

Sales transactions to buyers from other EU countries are also excluded from the REBU when the conditions for intra-Community exemption are met (the buyer has an intra-Community VAT number and the vehicle leaves Spanish territory).

Purchases from companies and sole traders: normal VAT even if the car is used

This is the most frequent source of error in the daily routine of dealerships. When a car is bought from a company or a sole trader who sold it with an invoice showing broken-down VAT, that transaction cannot be subject to the REBU.

Read also how to manage procedures and documents in B2B transactions.

The reasoning is as follows: the REBU exists to avoid double taxation of VAT in the second-hand market. When a private individual sells their car, they cannot charge VAT, so the dealership buying it from them has not deducted any VAT. The REBU allows the resale to be taxed only on the margin. But when the purchase was made with a VAT invoice (a company or sole trader who sold with VAT), the dealership did deduct that VAT. Upon resale, they must charge normal VAT so as not to have benefited twice.

The practical error is buying a car from a company with a VAT invoice, deducting that VAT in the return, and then selling it under REBU. The Tax Agency detects the inconsistency during a review because the car appears with deducted VAT on the purchase and without charged VAT on the sale.

Cars with an invoice without VAT: what it means and when it happens

In dealer groups, the phrase "this car has no VAT" is frequently heard, referring to an invoice that does not break down the VAT. What it usually means is one of these three situations, which have different implications.

The first is an invoice issued under REBU by another dealership. The VAT is included in the price but is not broken down. The buyer (another dealership) can resell the vehicle under REBU because the purchase was made from someone who already sold it under that scheme.

The second is an invoice from a private individual. Private individuals cannot charge VAT, so their invoice or receipt has no VAT. The vehicle can be resold under REBU because it was purchased from someone who could not charge VAT.

The third, less frequent, is an invoice from an entity exempt from VAT (foundations, non-profit entities, public bodies in certain activities). This also allows the application of the REBU on resale.

What matters before deciding on the tax scheme for resale is not whether the invoice has broken-down VAT or not, but whether the original seller could or could not charge VAT on that transaction.

Negative margin in REBU: what happens and how it is managed

A negative margin occurs when the sale price of the vehicle is lower than the purchase price: the car was sold at a loss. In the REBU, when the margin is negative, the taxable base of the VAT is zero: there is no VAT to settle for that transaction.

The negative margin cannot be offset against the positive margin of other transactions in the same period, unlike what happens in other schemes. Each transaction under REBU is calculated independently.

This has an important consequence: if in a quarter you have many transactions with a negative margin that could offset the positive ones, the REBU does not allow you to do so. Each transaction is separate. Therefore, in periods of a downward market where cars are frequently resold at a loss, the calculation must be made transaction by transaction.

Correct registration of negative margins is important in the event of an inspection: the Tax Agency can request the purchase and sale documentation for each vehicle to verify that the declared margins are correct.

Exports under REBU: the specific rules

When a vehicle is sold to a buyer in another EU country and the conditions for intra-Community exemption are met (the buyer has a valid intra-Community VAT number in VIES and the vehicle physically leaves Spain), the transaction is exempt from VAT.

See also what procedures are involved in exporting a car to another EU country.

This exemption is incompatible with the REBU. The REBU cannot be applied to an exempt intra-Community sale. The transaction is declared as an exempt intra-Community supply on form 349 and form 303.

For sales to countries outside the EU (exports), the transaction is also exempt from VAT if the vehicle physically leaves Community territory, regardless of the scheme (REBU or general) that was applied to the purchase.

In both cases, keeping the documentation that proves the vehicle left the territory (transport document, carrier invoice, confirmation of destination) is mandatory as support for the applied exemption.

REBU and Verifactu: how they relate

From 1 July 2025, all sole traders and companies in Spain must use certified billing software in compliance with the Verifactu system, which sends a record of each invoice issued to the AEAT in real time with a digital signature that guarantees its integrity.

Verifactu and the REBU are two systems that coexist but do not interfere with each other in terms of tax logic: the REBU determines how the VAT for each transaction is calculated, and Verifactu determines how the invoice is recorded and communicated to the Tax Agency. What Verifactu does is guarantee that the REBU invoice issued is unalterable and recorded with the AEAT.

The practical implication is that the billing software used by the dealership has to do two things correctly and simultaneously: issue the REBU invoice without broken-down VAT and with the correct legal reference, and send the Verifactu record to the AEAT in real time. A Verifactu-approved program that does not manage the REBU correctly remains a tax issue even if it complies with Verifactu.

Another implication of the REBU within Verifactu is the identification of the transaction type in the record sent to the AEAT. REBU invoices have a specific identifier in the Verifactu schema that distinguishes them from general scheme invoices. If the software incorrectly flags a REBU invoice as a general scheme in the Verifactu registry, there is an inconsistency between what is declared on form 303 and what is recorded with the AEAT, which can generate a request for clarification.

See what a REBU billing program for dealerships must comply with to see what to ask before hiring any software.


Frequent mistakes that cause problems with the Tax Agency

Applying the REBU to cars bought with an invoice showing broken-down VAT is the most serious and frequent error. The result is VAT deducted on the purchase and not charged on the sale, which the Tax Agency regularizes with the corresponding interest and surcharges.

Not keeping the purchase documentation for each vehicle is the second most common mistake. In an inspection, the Tax Agency can ask for justification of why the REBU was applied to each transaction. Without the purchase invoice or receipt proving that the seller did not charge VAT, the burden of proof falls on the dealership.

Read also the most common financial mistakes in a dealership.

Mixing vehicles under REBU and vehicles with general VAT on the same invoice is a documentary error that complicates accounting and can generate confusion in quarterly returns.

Applying the reduced rate of 4% in a transaction under REBU. As explained above, the REBU is always taxed at the general rate. The 4% only applies to transactions with normal broken-down VAT to buyers with duly accredited reduced mobility.

Dealcar and the tax control of transactions

From Dealcar, you can record the tax scheme of each transaction (REBU or normal VAT), the purchase price and sale price, and the resulting margin. The system automatically calculates the taxable base of each transaction and facilitates the preparation of quarterly returns without the need to do it manually.

Visit the electronic invoicing page for Dealcar dealerships.

This transaction-by-transaction traceability is what allows you to respond to any request from the Tax Agency with organized documentation.

If you want to see how tax control works in Dealcar, request a demo at dealcar.io.

Frequently Asked Questions

Can a dealership choose not to apply the REBU and use general VAT for all its cars?

Yes. The REBU is an optional scheme. A dealership can opt out of the REBU and pay general VAT on all its transactions. In practice, the REBU is more advantageous in most cases because it significantly reduces the VAT to be settled, but there may be specific situations where the general scheme is more convenient.

Does the REBU also apply to accessories and services included in the sale?

No. The REBU applies exclusively to the vehicle. If new accessories are sold along with the vehicle or an extended mechanical warranty is invoiced as a service, those items are taxed at the general VAT rate. Only the price of the vehicle can benefit from the REBU.

How is the REBU documented on the invoice?

The invoice issued under REBU must expressly indicate that the Special Scheme for Used Goods is applied. It must not break down the VAT. The total amount appearing on the invoice includes the VAT calculated on the margin, but the buyer does not see that VAT separated because they cannot deduct it.

What happens if the Tax Agency finds that I applied the REBU incorrectly in previous years?

The Tax Agency can regularize unpaid VAT amounts corresponding to the last four financial years plus late payment interest. If the error was involuntary and no information was concealed, the penalty can be reduced by cooperating with the inspection and making a voluntary regularisation. If the error was systematic or there are indications of concealment, the penalties can be higher. In case of any doubt about past transactions, consulting with your tax advisor before the inspection arrives is always the best option.

Index

  1. Quick recap: how the REBU works in the standard case

  2. How the REBU margin is calculated: formula and complete example

  3. Which expenses reduce the REBU margin and which do not

  4. The 4% VAT for reduced mobility: who can apply it and how

  5. When the REBU does not apply and general VAT must be used

  6. Purchases from companies and sole traders: normal VAT even if the car is used

  7. Cars with an invoice without VAT: what it means and when it happens

  8. Negative margin in REBU: what happens and how it is managed

  9. Exports under REBU: the specific rules

  10. REBU and Verifactu: how they relate

  11. Frequent mistakes that cause problems with the Tax Agency

  12. Dealcar and the tax control of transactions

  13. Frequently Asked Questions


Quick recap: how the REBU works in the standard case

The REBU (Special Scheme for Used Goods) is an optional VAT scheme that allows second-hand car dealerships to pay tax on the margin of the transaction instead of the total sale price. Under the general scheme, VAT is applied to the full sale price. Under the REBU, it is only applied to the difference between the sale price and the purchase price.

See the complete REBU guide for car dealerships for the standard case before reading the special cases.

The condition for applying the REBU is that the vehicle must have been acquired from someone who could not pass on VAT on the sale: a private individual, a dealership that already sold it under REBU, a company exempt from VAT, or a taxable person who acquired the asset for their own use.

The REBU VAT is not broken down on the invoice: the price that appears on the invoice to the buyer already includes the VAT on the margin, with no separate mention. This means that the buyer cannot deduct that VAT even if they are a business, and that the invoice issued under REBU does not generate break-downable output VAT.

How the REBU margin is calculated: formula and complete example

The REBU margin is the taxable base on which VAT is calculated. The formula is:

REBU Margin = Sale price − Purchase price − Deductible expenses

The VAT to be settled is: REBU Margin × 21% / 121

That division by 121 (and not multiplying directly by 21%) is because the sale price already includes the VAT on the margin. The VAT is inside the price, it is not added on top.

Read also what the REBU registry book must include and how to organize it.

Complete example with real numbers:

A dealership buys a Toyota RAV4 from a private individual for 14,500 euros. It pays 320 euros for transport from the seller's home and 480 euros for a workshop to repair the brakes and change the tyres. They sell it to a final buyer for 18,200 euros.

Margin calculation:

  • Sale price: €18,200

  • Purchase price: €14,500

  • Transport: €320

  • Repair: €480

  • REBU Margin: 18,200 − 14,500 − 320 − 480 = €2,900

VAT to be settled: 2,900 × 21 / 121 = €503.31

If the dealership had paid tax under the general scheme on the full sale price: 18,200 × 21% = 3,822 euros in VAT. The difference is more than 3,300 euros for this single transaction, which is the real saving that the REBU generates when applied correctly.

This margin of 2,900 euros is the figure recorded in the REBU registry book and added to the margins of the other transactions for the quarter to calculate box 25 of form 303.

See also the Verifactu landing page for Dealcar dealerships.

Which expenses reduce the REBU margin and which do not

This is the question that generates the most confusion in daily practice. Not all expenses associated with a vehicle reduce the REBU margin, and putting in expenses that do not apply is an error that the Tax Agency can detect in an inspection.

Expenses that DO reduce the REBU margin:

The transport of the vehicle from the point of purchase to the dealership or to the final customer is expressly recognized as a deductible expense of the REBU margin. It must be documented with an invoice from the carrier that includes the vehicle reference (registration plate or VIN).

The repairs necessary to put the vehicle in saleable condition also reduce the margin. These are the mechanical or bodywork jobs that the car needs before it can be sold: brake changes, tyre replacement, bodywork repair, replacement of defective parts. They must be documented with an invoice from the workshop with the vehicle reference.

Expenses that DO NOT reduce the REBU margin:

The commercial warranty offered to the buyer does not reduce the REBU margin even if it is included in the sale price. If the warranty is invoiced separately, it is taxed at the general rate of 21% as an independent service.

General business expenses (rent of the premises, listing portals, management tools, staff payroll, business insurance) are structural expenses that are not attributable to a specific vehicle and do not reduce the REBU margin. They are deducted as business expenses in the personal income tax (IRPF) or Corporate Tax, but not in the calculation of the REBU margin.

Aesthetic preparation expenses (cleaning, polishing, interior detailing) are in a grey area: the VAT Law only expressly mentions transport and repairs as deductible expenses of the margin. Pure aesthetic expenses are not repairs and their deductibility is not clearly recognized. The most prudent stance is not to include them in the margin and to consult with your tax advisor if the amount is significant.

The agency fees for the transfer also do not reduce the REBU margin. It is a business cost that is tax-deducted in another way.

Summary table:

Expense

Does it reduce the REBU margin?

Vehicle transport

Yes

Mechanical repairs

Yes

Bodywork repair

Yes

Commercial warranty

No

Aesthetic preparation expenses

No (grey area)

Portals and advertising

No

Transfer agency fees

No

Rent of the premises

No


The 4% VAT for reduced mobility: who can apply it and how

The reduced VAT rate of 4% for vehicles intended for people with reduced mobility is one of the special cases that generates the most confusion. It is regulated in Article 91 of the VAT Law and in Royal Decree 1576/2006.

For the 4% rate to be applied, three conditions must be met simultaneously. The first is that the buyer must be a person with a recognized disability with a degree equal to or greater than 33% in the case of physical disabilities, or equal to or greater than 65% in the case of mental or sensory disabilities. The second is that the vehicle will be used exclusively or mainly by that person. The third is that the vehicle does not exceed the established limits regarding engine capacity and type: currently, it applies to passenger cars and other motor vehicles up to 2,000 cc in the case of petrol and up to 2,500 cc in the case of diesel.

The application process requires the buyer to provide the dealership with the supporting documentation: the certificate of disability issued by IMSERSO or by the corresponding autonomous community and a solemn declaration indicating that the vehicle will be used for their personal use. The dealership must keep this documentation as proof of the application of the reduced rate.

See also which financial company to choose for customers with special needs.

A key point that generates confusion: the 4% rate applies to VAT, not to the REBU. If the vehicle is purchased under REBU, the REBU does not contemplate reduced rates: the margin is always taxed at the general rate of 21%. The 4% VAT is only applicable in transactions with broken-down VAT, i.e., when the transaction is not done under REBU but with normal VAT on the sale price.

In practice, this means that to apply the 4% VAT to a buyer with reduced mobility, the dealership has to sell the car with normal VAT (not under REBU), which implies that they must have purchased the vehicle with an invoice showing broken-down VAT. If the dealership bought the car from a private individual (without VAT) and intends to sell it with 4%, they cannot: they have no input VAT to offset and the REBU does not allow reduced rates.

Cuándo el REBU no aplica y hay que usar IVA general

The REBU is not applicable in all cases. There are situations in which the dealership must use the general VAT scheme even if the vehicle is second-hand.

The most frequent is the purchase of a vehicle from a company or sole trader who sold it with broken-down VAT on their invoice. If the seller charged VAT on the transaction, the buyer (the dealership) deducted that VAT. When reselling the vehicle, they must charge VAT at the general rate because they already benefited from the deduction upon purchase.

Another situation is the import of vehicles from countries outside the EU, where the vehicle has paid import VAT at customs upon entering Spain. That VAT is deductible for the dealership, which must charge normal VAT when reselling the vehicle.

Sales transactions to buyers from other EU countries are also excluded from the REBU when the conditions for intra-Community exemption are met (the buyer has an intra-Community VAT number and the vehicle leaves Spanish territory).

Purchases from companies and sole traders: normal VAT even if the car is used

This is the most frequent source of error in the daily routine of dealerships. When a car is bought from a company or a sole trader who sold it with an invoice showing broken-down VAT, that transaction cannot be subject to the REBU.

Read also how to manage procedures and documents in B2B transactions.

The reasoning is as follows: the REBU exists to avoid double taxation of VAT in the second-hand market. When a private individual sells their car, they cannot charge VAT, so the dealership buying it from them has not deducted any VAT. The REBU allows the resale to be taxed only on the margin. But when the purchase was made with a VAT invoice (a company or sole trader who sold with VAT), the dealership did deduct that VAT. Upon resale, they must charge normal VAT so as not to have benefited twice.

The practical error is buying a car from a company with a VAT invoice, deducting that VAT in the return, and then selling it under REBU. The Tax Agency detects the inconsistency during a review because the car appears with deducted VAT on the purchase and without charged VAT on the sale.

Cars with an invoice without VAT: what it means and when it happens

In dealer groups, the phrase "this car has no VAT" is frequently heard, referring to an invoice that does not break down the VAT. What it usually means is one of these three situations, which have different implications.

The first is an invoice issued under REBU by another dealership. The VAT is included in the price but is not broken down. The buyer (another dealership) can resell the vehicle under REBU because the purchase was made from someone who already sold it under that scheme.

The second is an invoice from a private individual. Private individuals cannot charge VAT, so their invoice or receipt has no VAT. The vehicle can be resold under REBU because it was purchased from someone who could not charge VAT.

The third, less frequent, is an invoice from an entity exempt from VAT (foundations, non-profit entities, public bodies in certain activities). This also allows the application of the REBU on resale.

What matters before deciding on the tax scheme for resale is not whether the invoice has broken-down VAT or not, but whether the original seller could or could not charge VAT on that transaction.

Negative margin in REBU: what happens and how it is managed

A negative margin occurs when the sale price of the vehicle is lower than the purchase price: the car was sold at a loss. In the REBU, when the margin is negative, the taxable base of the VAT is zero: there is no VAT to settle for that transaction.

The negative margin cannot be offset against the positive margin of other transactions in the same period, unlike what happens in other schemes. Each transaction under REBU is calculated independently.

This has an important consequence: if in a quarter you have many transactions with a negative margin that could offset the positive ones, the REBU does not allow you to do so. Each transaction is separate. Therefore, in periods of a downward market where cars are frequently resold at a loss, the calculation must be made transaction by transaction.

Correct registration of negative margins is important in the event of an inspection: the Tax Agency can request the purchase and sale documentation for each vehicle to verify that the declared margins are correct.

Exports under REBU: the specific rules

When a vehicle is sold to a buyer in another EU country and the conditions for intra-Community exemption are met (the buyer has a valid intra-Community VAT number in VIES and the vehicle physically leaves Spain), the transaction is exempt from VAT.

See also what procedures are involved in exporting a car to another EU country.

This exemption is incompatible with the REBU. The REBU cannot be applied to an exempt intra-Community sale. The transaction is declared as an exempt intra-Community supply on form 349 and form 303.

For sales to countries outside the EU (exports), the transaction is also exempt from VAT if the vehicle physically leaves Community territory, regardless of the scheme (REBU or general) that was applied to the purchase.

In both cases, keeping the documentation that proves the vehicle left the territory (transport document, carrier invoice, confirmation of destination) is mandatory as support for the applied exemption.

REBU and Verifactu: how they relate

From 1 July 2025, all sole traders and companies in Spain must use certified billing software in compliance with the Verifactu system, which sends a record of each invoice issued to the AEAT in real time with a digital signature that guarantees its integrity.

Verifactu and the REBU are two systems that coexist but do not interfere with each other in terms of tax logic: the REBU determines how the VAT for each transaction is calculated, and Verifactu determines how the invoice is recorded and communicated to the Tax Agency. What Verifactu does is guarantee that the REBU invoice issued is unalterable and recorded with the AEAT.

The practical implication is that the billing software used by the dealership has to do two things correctly and simultaneously: issue the REBU invoice without broken-down VAT and with the correct legal reference, and send the Verifactu record to the AEAT in real time. A Verifactu-approved program that does not manage the REBU correctly remains a tax issue even if it complies with Verifactu.

Another implication of the REBU within Verifactu is the identification of the transaction type in the record sent to the AEAT. REBU invoices have a specific identifier in the Verifactu schema that distinguishes them from general scheme invoices. If the software incorrectly flags a REBU invoice as a general scheme in the Verifactu registry, there is an inconsistency between what is declared on form 303 and what is recorded with the AEAT, which can generate a request for clarification.

See what a REBU billing program for dealerships must comply with to see what to ask before hiring any software.


Frequent mistakes that cause problems with the Tax Agency

Applying the REBU to cars bought with an invoice showing broken-down VAT is the most serious and frequent error. The result is VAT deducted on the purchase and not charged on the sale, which the Tax Agency regularizes with the corresponding interest and surcharges.

Not keeping the purchase documentation for each vehicle is the second most common mistake. In an inspection, the Tax Agency can ask for justification of why the REBU was applied to each transaction. Without the purchase invoice or receipt proving that the seller did not charge VAT, the burden of proof falls on the dealership.

Read also the most common financial mistakes in a dealership.

Mixing vehicles under REBU and vehicles with general VAT on the same invoice is a documentary error that complicates accounting and can generate confusion in quarterly returns.

Applying the reduced rate of 4% in a transaction under REBU. As explained above, the REBU is always taxed at the general rate. The 4% only applies to transactions with normal broken-down VAT to buyers with duly accredited reduced mobility.

Dealcar and the tax control of transactions

From Dealcar, you can record the tax scheme of each transaction (REBU or normal VAT), the purchase price and sale price, and the resulting margin. The system automatically calculates the taxable base of each transaction and facilitates the preparation of quarterly returns without the need to do it manually.

Visit the electronic invoicing page for Dealcar dealerships.

This transaction-by-transaction traceability is what allows you to respond to any request from the Tax Agency with organized documentation.

If you want to see how tax control works in Dealcar, request a demo at dealcar.io.

Frequently Asked Questions

Can a dealership choose not to apply the REBU and use general VAT for all its cars?

Yes. The REBU is an optional scheme. A dealership can opt out of the REBU and pay general VAT on all its transactions. In practice, the REBU is more advantageous in most cases because it significantly reduces the VAT to be settled, but there may be specific situations where the general scheme is more convenient.

Does the REBU also apply to accessories and services included in the sale?

No. The REBU applies exclusively to the vehicle. If new accessories are sold along with the vehicle or an extended mechanical warranty is invoiced as a service, those items are taxed at the general VAT rate. Only the price of the vehicle can benefit from the REBU.

How is the REBU documented on the invoice?

The invoice issued under REBU must expressly indicate that the Special Scheme for Used Goods is applied. It must not break down the VAT. The total amount appearing on the invoice includes the VAT calculated on the margin, but the buyer does not see that VAT separated because they cannot deduct it.

What happens if the Tax Agency finds that I applied the REBU incorrectly in previous years?

The Tax Agency can regularize unpaid VAT amounts corresponding to the last four financial years plus late payment interest. If the error was involuntary and no information was concealed, the penalty can be reduced by cooperating with the inspection and making a voluntary regularisation. If the error was systematic or there are indications of concealment, the penalties can be higher. In case of any doubt about past transactions, consulting with your tax advisor before the inspection arrives is always the best option.

Continue reading

Related blogs