Index
What is the Register of Intra-Community Operators (ROI) and what is it for
Who must register in the ROI
How intra-Community VAT works when purchasing vehicles in the EU
How to register in the ROI: the step-by-step process
Documentation required for registration
What happens if a car is purchased in the EU without being registered in the ROI
Vehicle documentation for legal import into Spain
The Certificate of Conformity (COC): what it is and when it is necessary
Total costs of an import from the EU
Dealcar and managing imported stock
Frequently asked questions
What is the Register of Intra-Community Operators (ROI) and what is it for
The Register of Intra-Community Operators (ROI) is a census of the Spanish Tax Agency in which companies and sole traders who carry out commercial transactions with European Union countries are registered. Registration in the ROI provides an Intra-Community Tax Identification Number (VAT number), which is the key that allows buying from European suppliers without paying VAT in the country of origin.
The mechanism is as follows: when two operators registered in the ROI of their respective countries carry out an intra-Community transaction, the seller issues the invoice without VAT. The buyer declares that acquisition in their country and self-assesses the VAT: they charge and deduct it simultaneously in the same tax return. The net effect for the buyer is zero in terms of cash flow, because the VAT declared as input tax and the one declared as output tax offset each other.
Check the comparison of car auction platforms for dealerships.
Without a VAT number, the European seller must apply their country's VAT on the invoice. That foreign VAT cannot be directly recovered in Spain. The Spanish buyer can request the refund of the foreign VAT through the AEAT's refund procedure for non-established entities, but it is a slow and not always efficient process.
For a dealership that imports 5 or 10 cars a month from Germany at an average price of €15,000, the German VAT (19%) that could be avoided with an active ROI represents an impact of between €14,250 and €28,500 monthly on cash flow. Although this VAT can be recovered later, having it tied up while the refund is processed has a real cost.
Who must register in the ROI
Any dealership that buys vehicles directly from suppliers in other EU countries (European auctions, European leasing platforms, German, French, or Belgian dealers) must be registered in the ROI to correctly manage the VAT of those operations.
Dealerships that sell vehicles to buyers with a VAT number from other EU countries also need the ROI, although this is less common in the Spanish used vehicle market.
Dealerships that buy all their vehicles in Spain do not need the ROI, even if they buy from platforms like Openlane or eCarsTrade which have headquarters in Spain. The key is not the platform but where the vehicle seller is located and whether they issue the invoice as a European operator.
How intra-Community VAT works when purchasing vehicles in the EU
The VAT treatment when importing vehicles from the EU depends on the type of seller.
If the seller is a European company registered in the ROI of their country (leasing company, corporate fleet, professional platform), they issue the invoice without VAT if the Spanish buyer has an active VAT number. The Spanish buyer declares the intra-Community acquisition in their form 303 and in form 349 (recapitulative statement of intra-Community transactions). VAT is self-assessed with no net impact.
If the seller is a European individual (a natural person without a VAT number), the transaction is not an intra-Community transaction between operators. The Spanish buyer can apply the special scheme for new or used means of transport according to the corresponding criteria. For used vehicles purchased from individuals in the EU, VAT is settled in Spain and the REBU (Special Scheme for Used Goods) can be applied upon resale if the requirements are met.
Read also the special cases of REBU: when it applies and when it does not.
If the seller is a European company that does not have an active VAT number or whose VAT number is not verified at the time of the transaction, the Spanish buyer may face issues when deducting VAT in Spain. Verifying the supplier's VAT number before each transaction in the European Commission's VIES (VAT Information Exchange System) is a highly recommended practice.
How to register in the ROI: the step-by-step process
Registration in the ROI is processed by submitting Form 036 (Census Declaration) checking the box corresponding to intra-Community activity. The procedure can be done in person at the AEAT office corresponding to the tax address, or online through the AEAT electronic office using a digital certificate or Cl@ve.
On Form 036, you must check box 582 (application for registration in the ROI) and indicate in box 584 the planned date of the first intra-Community transaction. It is important that this date is realistic: if the registration is requested before having a specific transaction, the AEAT may request justification of the planned intra-Community activity.
The AEAT has a period of three months to resolve the application. If there is no response within that period, the application is understood to be rejected. In practice, resolutions usually occur within 2 to 6 weeks when the documentation is complete and the applicant's activity clearly justifies intra-Community operations.
Registration in the ROI is not permanent: the AEAT can exclude operators from the register if they do not effectively carry out intra-Community transactions or if they present tax irregularities. Keeping Form 349 updated with each intra-Community transaction is the way to prove real activity.
Documentation required for registration
Registration in the ROI requires submitting a correctly completed Form 036. Depending on the applicant's profile, the AEAT may request additional documentation justifying the planned intra-Community transactions: contracts with European suppliers, proforma invoices, or any document proving the commercial relationship with the EU.
For limited companies or corporations, the deed of incorporation and proof of representation may also be requested. For sole traders, a valid ID card (DNI) and registration in the IAE (Economic Activities Tax) under the heading corresponding to vehicle sales are required.
What happens if a car is purchased in the EU without being registered in the ROI
If the dealership buys a vehicle from a European company without having an active VAT number, the supplier is obliged to invoice with the VAT of their country. That foreign VAT appears on the purchase invoice and cannot be directly deducted on the Spanish Form 303.
The alternative is to request a refund of the foreign VAT through the refund procedure for non-established entities, which is processed through the AEAT electronic office. It is a valid procedure but slower and involves more management than standard operations with an active ROI.
From the perspective of the Spanish tax return, an intra-Community acquisition carried out without a VAT number can also generate discrepancies during tax reviews if the AEAT detects that there are transactions with European suppliers that have not been declared as intra-Community acquisitions.
Vehicle documentation for legal import into Spain
Importing a vehicle from another EU country to Spain requires completing the documentation in two blocks: commercial transaction documentation and documentation for registration or transfer of the vehicle in Spain.
For the commercial transaction: the purchase invoice issued by the European supplier with the correct details (VAT number of both buyer and seller, full description of the vehicle with VIN, price), the purchase agreement if there are additional terms, and proof of payment.
For registration in Spain: the Certificate of Conformity (COC) if the model is not previously registered in Spain with a recognized type-approval number, the vehicle's technical sheet, the de-registration certificate or ownership document from the country of origin, and proof of payment of the Registration Tax if applicable based on the vehicle's features.
See also how to check for outstanding liens and seizures before buying a vehicle.
The Certificate of Conformity (COC): what it is and when it is necessary
The Certificate of Conformity (COC) is the document proving that a vehicle complies with European type-approval standards. It is issued by the manufacturer and is necessary to register a vehicle from another EU country in Spain when that vehicle does not already have a Spanish registration plate or when it is a vehicle that has not been officially commercialised in Spain.
For most models of European brands or those with an official presence in Spain (Volkswagen, BMW, Renault, Toyota), the COC is available through the official importer and the process is standard. For models with specific configurations from the country of origin (right-hand drive versions, models not sold in Spain), the process can be more complex and require individual type-approval.
When the vehicle is already registered in another EU country and the process is to transfer that vehicle to the Spanish registry (de-registration in the country of origin and registration in Spain), the COC can be replaced by the vehicle registration certificate of the country of origin in some cases. The corresponding Provincial Traffic Headquarters is the one that determines the exact requirements based on the specific vehicle.
Total costs of an import from the EU
The purchase price of the vehicle is not the only cost of an import. To calculate the actual margin of the operation, all additional costs must be included from origin until the vehicle is ready for sale in Spain.
Transport from the country of origin to the dealership in Spain is the first additional cost. For vehicles coming from Germany, France, or Belgium, the cost of transport by car transporter truck ranges between €300 and €550 depending on the point of origin and destination. For vehicles coming from more distant countries (Poland, Czech Republic, Netherlands), it can exceed €600.
Check how to organise and calculate the cost of car transport.
Import procedures include managing the de-registration in the country of origin (if the vehicle was registered there), the sworn translation of documents if required by the Traffic Headquarters, and the registration fees for the Spanish license plate. Depending on the complexity, these procedures can cost between €150 and €400 through a specialised agency.
The Registration Tax is applied to vehicles that exceed certain emission limits. Vehicles with CO2 emissions above 120 g/km pay between 4.75% and 14.75% of the purchase price as IEDMT (Special Tax on Certain Means of Transport). Vehicles with emissions below 120 g/km are exempt. For older diesel vehicles or those with high mileage, this tax can be a significant cost that must be calculated before bidding.
Read also which expenses are part of the real cost of a car in a dealership sale.
More than 750 dealerships already use Dealcar to manage their daily operations
Dealcar allows you to register the origin of each vehicle (import from which country, purchase platform, type of seller) and link all import costs to the vehicle file to calculate the real net margin of the operation.
The market radar allows you to compare the price of similar vehicles in the Spanish market before deciding how much to pay at origin. Compare the market price in Spain before buying at origin with Dealcar's market radar.
You can see how it works at dealcar.io/software-concesionario or request a demo at dealcar.io.
Frequently asked questions
Is registration in the ROI free of charge?
Yes. Registering in the ROI using Form 036 is free. The only costs are those of the agency if you decide to delegate the process, which is usually between €50 and €150.
How long does the AEAT take to resolve registration in the ROI?
The legal period is three months, but in practice, the resolution usually arrives sooner. With complete documentation and a clearly justified activity (contract with a European supplier, proforma invoices), the usual timeframe is 2 to 6 weeks.
Do I have to submit Form 349 even if I only import cars occasionally?
Yes. Form 349 is mandatory to declare every intra-Community transaction, regardless of frequency. If there are no intra-Community transactions in a quarter, you do not need to submit Form 349 for that period. But if there is even just one transaction, it must be declared.
Can I buy from a European individual using the VAT number?
No. The VAT number only applies to transactions between operators (companies or sole traders). If the seller is a European individual without a VAT number, the transaction is not an intra-Community one between operators, and the VAT is managed differently depending on the type of vehicle.
Does the Registration Tax apply to all cars imported from the EU?
No. Only to those that exceed the established emission limits. Vehicles with less than 120 g/km of CO2 are exempt. For petrol cars older than 10 years and high-displacement diesel vehicles, it is important to calculate this tax before deciding to import.
