Cross-border car invoice: what an EU sales invoice needs
Cross-border car invoice requirements in the EU: mandatory details, VAT exemption wording, margin scheme mention, VIN and mileage for used car sales.
· 6 min read
A cross-border car invoice in the EU must contain the details listed in Article 226 of the VAT Directive: date, sequential number, both parties' names, addresses and VAT numbers, a description of the car, the net price and either the VAT or the reason no VAT is shown. For a VAT-free intra-EU sale add an exemption reference; for a margin car, the mention "Margin scheme — Second-hand goods".
Cross-border car invoice: what an intra-EU sale invoice must contain
An intra-EU car invoice must contain every detail required by Article 226 of Directive 2006/112/EC, plus the vehicle data that the buyer's registration office will ask for. Member states have transposed the list almost word for word, so an invoice that meets Article 226 is accepted across the EU.
| Article 226 point | Detail | Car-specific tip |
|---|---|---|
| (1) | Date of issue | Use the delivery date or a date shortly after it |
| (2) | Sequential number | One unbroken series, also for export sales |
| (3) | Your VAT number | The number from the country where the car is |
| (4) | Buyer's VAT number | Required for intra-community supplies; check in VIES |
| (5) | Full names and addresses | Exactly as in the company register |
| (6) | Quantity and nature of goods | Make, model, version, VIN |
| (7) | Date of supply | If different from the invoice date |
| (8)–(10) | Taxable amount, rate, VAT amount | Not shown for margin cars |
| (11) | Exemption reference | Needed for VAT-free supplies |
| (12) | New means of transport data | First entry into service and km for young cars |
| (14) | Margin scheme mention | "Margin scheme — Second-hand goods" |
Under Article 230 the amounts may be in any currency, but any VAT payable must also be expressed in the national currency of the member state concerned. That matters when a Polish or Czech dealer sells in euros.
When must the invoice be issued?
For an intra-community supply under Article 138, the invoice must be issued no later than the fifteenth day of the month following the supply (Article 222). For domestic and margin sales, national rules apply, but issuing on delivery is the safest habit. The invoice date also triggers the buyer's acquisition VAT in his country, so a late invoice causes problems at both ends.
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Request accessWhich wording is needed for a VAT-exempt supply?
Article 226(11) requires a reference to the provision of the Directive, the corresponding national provision or "any other reference indicating that the supply … is exempt". A clear sample text:
VAT-exempt intra-Community supply of goods – Article 138(1) Directive 2006/112/EC. Customer VAT ID: DE123456789.
Add the national wording if you invoice in your own language, for example "Steuerfreie innergemeinschaftliche Lieferung" in Germany or "Livraison intracommunautaire exonérée" in France. Do not write "reverse charge" alone on an intra-community supply of goods. Article 226(11a) requires the mention "Reverse charge" only where the customer is liable for VAT on the supply itself, typically domestic reverse-charge cases or services.
The invoice is only one part of the evidence; the conditions for zero-rating are explained in intra-community supply of cars.
How must a margin-scheme car be described on the invoice?
A margin-scheme invoice must carry the mention "Margin scheme — Second-hand goods" or its official equivalent (Article 226(14)) and must not show VAT separately (Article 325). The buyer cannot deduct any VAT on such a car (Article 323), so showing a VAT figure can mislead a business customer into claiming it.
Sample text:
Margin scheme – Second-hand goods (Article 313 Directive 2006/112/EC). Price includes VAT, which is not shown separately.
Use the national term too, such as "Gebrauchtgegenstände/Sonderregelung" in Germany, "Régime particulier – Biens d'occasion" in France or "Bijzondere regeling – gebruikte goederen" in the Netherlands. A margin car sold to a dealer in another member state is still invoiced this way, gross and without the buyer's VAT number as a condition. More layouts are in our VAT margin scheme invoice example.
Young cars: the new means of transport data
If the car was supplied within six months of first entry into service or has travelled no more than 6,000 km, it is a "new means of transport" for VAT. When such a car is sold VAT-free to another member state, Article 226(12) requires the invoice to show the characteristics defined in Article 2(2)(b): in practice, the date of first entry into service and the mileage.
This applies even when the buyer is a private person, who then pays VAT in his own country. See new means of transport VAT for the full rule.
Should the VIN and mileage appear on the invoice?
Yes. Article 226(6) only asks for the "quantity and nature" of the goods, but for a car that should mean the VIN, because registration offices, buyers' accountants and tax inspectors match documents by VIN. The mileage at delivery protects you against later disputes about odometer readings and is essential for young cars.
A complete vehicle block on a cross-border invoice:
- make, model, version and engine;
- VIN (17 characters, checked against the registration certificate);
- date of first registration;
- mileage at delivery;
- colour and registration number, if still registered;
- documents handed over: registration certificate parts, certificate of conformity, service book, number of keys.
Registration offices in several countries refuse imported cars when the VIN on the invoice differs from the vehicle, even by one character. Copy it from the registration certificate and check it on the car.
Car dealer invoice software: what to look for
Most general accounting tools can produce a correct invoice, but car dealer invoice software saves errors on cross-border deals. Look for:
- separate templates for domestic VAT, margin scheme, intra-community supply and export;
- automatic VIES check with stored consultation number;
- VIN, mileage and first-registration fields that print on the invoice;
- one sequential numbering series across all templates;
- an EC sales list export that uses the invoice data.
If you are choosing a system, our guide to car dealer software covers stock management and accounting links. MyCarDealer works before the invoice: it shows whether a car bought abroad leaves a margin at home after VAT and costs; you can try it with the free valuation.
Frequently asked questions
What must an invoice for an intra-EU car sale contain?
The details in Article 226 of the VAT Directive: date, sequential number, both VAT numbers, names and addresses, description of the car, date of supply, net price and an exemption reference. Add the VIN, first registration date and mileage.
Which wording is needed for a VAT-exempt supply?
A reference to the exemption, for example "VAT-exempt intra-Community supply – Article 138(1) Directive 2006/112/EC", together with the buyer's VAT number. The national equivalent in your own language is also accepted.
How must a margin-scheme car be described on the invoice?
With the mention "Margin scheme — Second-hand goods" or the national equivalent, and without VAT shown separately. This applies to domestic and cross-border sales of margin cars alike.
Should the VIN and mileage appear on the invoice?
Yes. The VIN identifies the car for registration, tax and audit purposes, and the mileage protects you in disputes. For cars under six months old or with up to 6,000 km, the first entry into service and mileage are legally required on a VAT-free cross-border invoice.
What is the deadline for an intra-community invoice?
No later than the fifteenth day of the month following the supply, under Article 222 of the VAT Directive. Issuing it on delivery is better practice.