AutoSmart GuidebooksWhat this guidebook covers
From 1 January 2027, companies that are not in the SII (Immediate Supply of Information) must invoice with Verifactu software. Using non-compliant software costs €50,000 per financial year. In VAT, applying the wrong scheme is fined up to 150% of the tax due, and above €120,000 of unpaid tax it is a tax crime with 1 to 5 years in prison.
This guidebook covers 6 tax standards for dealers, with 13 checkpoints: Verifactu or SII, complete invoices, the margin scheme for used goods (REBU), vehicle registration tax by CO2 band, intra-EU sales, and SII records sent on time. The guidebook PDF is in Spanish.
The 6 tax standards
Open a standard to see the law behind it, what is checked, what it can cost and the evidence. Ideal fix times are counted from audit submission.
FIS-01Verifactu or SII30 days
- The law
- General Tax Act (Law 58/2003) · VAT Act (Law 37/1992) · RD 1007/2023: invoicing systems (Verifactu) · SII
- What we check
- Companies on the SII (over €6 million) send their records within 4 days. The others use Verifactu-certified invoicing software from 1.1.2027.
- What it can cost
- €50,000 per financial year.
- Evidence
- Supplier's statement of conformity
FIS-02Complete invoices7 days
- The law
- General Tax Act (Law 58/2003) · VAT Act (Law 37/1992) · Royal Decree 1619/2012: invoicing obligations
- What we check
- Every invoice has all the details (tax ID, VIN, taxable amount, rate, tax), and corrections are made with a corrective invoice, never by deleting.
- What it can cost
- A fine of 1% of the amount of the incorrect invoices.
- Evidence
- Invoices
FIS-03REBU applied correctly30 days
- The law
- General Tax Act (Law 58/2003) · VAT Act (Law 37/1992) · LIVA arts. 135–139: special scheme for used goods (REBU)
- What we check
- REBU is applied only to cars bought from private individuals or from other dealers using REBU. If the car was bought with deductible VAT, it is invoiced with standard VAT.
- What it can cost
- The tax, interest and a fine of 50–150%.
- Evidence
- Purchase invoices
FIS-04Registration tax7 days
- The law
- General Tax Act (Law 58/2003) · VAT Act (Law 37/1992) · Law 38/1992: special tax on certain means of transport (IEDMT)
- What we check
- Each registration applies the right band for the car's WLTP CO2 emissions and the tax is paid (form 576) before registration.
- What it can cost
- The tax, interest and a fine of 50–150%.
- Evidence
- Forms 576
FIS-05Intra-EU sales7 days
- The law
- General Tax Act (Law 58/2003) · VAT Act (Law 37/1992) · LIVA art. 25: exempt intra-EU supplies · proof of transport
- What we check
- Exempt sales to other EU countries have the buyer's VAT number validated in VIES and proof that the car left Spain. Applies to dealers selling cars to customers in other EU countries.
- What it can cost
- The VAT is claimed, plus interest and a fine.
- Evidence
- VIES + CMR
FIS-06SII on time72 hours
- The law
- General Tax Act (Law 58/2003) · VAT Act (Law 37/1992) · RIVA art. 62.6: Immediate Supply of Information (turnover over €6 million)
- What we check
- Companies on the SII send the records of invoices issued and received within 4 working days at most. Applies to companies with turnover over €6 million or registered voluntarily.
- What it can cost
- 0.5% of the amount, up to €6,000 per quarter.
- Evidence
- SII report
How to run a Spanish tax, Verifactu and VAT audit, step by step
- Confirm what applies. Confirm whether the company is in the SII (turnover above €6 million) or must use Verifactu from 2027. The Basque Country and Navarre have their own systems (TicketBAI).
- Walk the site, standard by standard. Score each of the 13 checkpoints Pass, Fail or N/A. N/A only where the standard rules it out, with the reason recorded. Ask the DMS provider for the Verifactu certificate, then review 20 invoices, 10 REBU sales, 10 registration tax returns (form 576), 5 intra-EU sales and the SII dashboard.
- Capture the evidence. A pass counts only with proof captured at the time of the audit: the software provider's responsible declaration, invoices, purchase invoices for REBU cars, form 576 returns, VIES checks and CMR transport documents, and the SII report.
- Give every fail an owner and a fix time. Record what you saw and who owns the fix. Each standard carries an ideal fix time, from 72 hours to 30 days, counted from audit submission (see the table above).
- Fix it, then prove it. The site fixes the cause and uploads proof of closure; the auditor checks the proof before closing the finding.
- Re-check at the next audit. Confirm closed findings stay closed, and look for the same fail at your other sites so one gap doesn't repeat across the network.
Who this guidebook is for
- Finance directors: control systems and VAT schemes
- Administration: issues and records invoices
- Auditors: review invoices, REBU and tax returns
A reference document, not legal advice. Fines and rules change: check the current text with the regulator or your legal adviser before acting.
