Which documents should you keep per car for the margin scheme?

For each margin car you keep three things: a purchase statement signed by the seller, with date and registration number, an overview of the purchase and sale of that car, and a copy of the sales invoice with the wording "bijzondere regeling - gebruikte goederen" (special scheme for second-hand goods). The purchase statement is mandatory if you pay € 500 or more. You keep the records for 7 years.

The burden of proof is on you. The margin scheme is a favourable exception, so you must make it plausible that you meet the conditions. If you cannot, the Belastingdienst charges VAT on the full selling price. A car dealer found that out for 72 cars, with an additional assessment of € 107,802.

In this article

1. Which documents belong with every margin car?
2. What must be on the purchase statement?
3. What is a margin sheet and why do you need it?
4. What do you put on the sales invoice for a margin car?
5. What went wrong in the € 107,802 case?
6. Can you still prove afterwards that a car was a margin car?
7. Why does the Belastingdienst pay so much attention to this paper trail?

Which documents belong with every margin car?

A paper trail from purchase to sale. The law requires a purchase statement, records that show the profit margin and an invoice without VAT (Belastingdienst, administrative obligations for margin goods). It is also wise to keep the proof of payment and the RDW papers in the same file.

You keep the records for 7 years (Belastingdienst, keeping records). A car you sell in January can therefore still be the subject of a tax audit years later.

What must be on the purchase statement?

Seven details, and the seller signs. You give the statement to the seller, he signs it and you keep a copy (VAT Implementing Decree, article 4a). The statement shows:

1. the day of delivery
2. name and address of your business
3. name and address of the seller
4. a clear description of the car, with the registration number
5. the quantity
6. the amount you pay
7. a statement from the seller that he did not deduct any VAT on the car

The statement is mandatory if you buy for € 500 or more from one supplier (Belastingdienst, drawing up a purchase statement). There are two exceptions that matter for the car trade. With a trade-in, your invoice to the customer counts as the purchase statement, if it also shows all details of the traded-in car. And if you buy from a business using the KOR, it must declare that it applies the KOR.

Also put the chassis number on it, even though the law does not require it. In the case below, the inspector pointed precisely at statements without a date and without a registration or chassis number, which therefore could not be linked to a specific car (Court of Appeal Arnhem-Leeuwarden, ECLI:NL:GHARL:2025:1272).

What is a margin sheet and why do you need it?

A margin sheet is an overview per car of purchase, sale and margin. The term is not in the law, but the obligation behind it is: you record margin goods and margin sales separately, and your books must clearly show the profit margin (Belastingdienst, administrative obligations for margin goods).

You also keep regular records of the invoices and purchase statements you issue, numbered consecutively, with date, name and address, description and amount (VAT Implementing Decree, article 31). A margin sheet per car, or one line per car in a stock register, fulfils that obligation in practice.

Put on the margin sheet: registration number, make and model, purchase date, bought from whom, margin car or VAT car, purchase price, number of the purchase statement, sale date, selling price, invoice number and margin. Keep refurbishment costs separately alongside. They do not reduce the margin, but you do deduct the VAT on parts (Belastingdienst, VAT when repairing margin goods).

What do you put on the sales invoice for a margin car?

No VAT, but the fixed wording "bijzondere regeling - gebruikte goederen" (special scheme for second-hand goods). Otherwise the invoice must meet the normal invoice requirements (Belastingdienst, administrative obligations for margin goods). A handwritten note such as "margin" is therefore not enough.

In the € 107,802 case, the dealer wrote his invoices by hand. The VAT rate was crossed out and "Marge" was written next to it. Consecutive numbering, the delivery date, the buyer's address and a proper description of the car were missing (District Court of Northern Netherlands, ECLI:NL:RBNNE:2023:2202).

What went wrong in the € 107,802 case?

The dealer could not prove for 72 cars that they were margin cars: 11 in the fourth quarter of 2014 and 61 in 2015. Purchase statements were missing, or they were undated and without a registration or chassis number. The Belastingdienst imposed an additional assessment, after objection € 107,802, plus € 15,820 tax interest (District Court of Northern Netherlands, ECLI:NL:RBNNE:2023:2202).

The assessment also contained other corrections, but the rejected margin scheme was the largest item. Over those five quarters together, the dealer had on balance even declared a negative amount of VAT. There were no books, only loose papers that an adviser added up each quarter. The cash book was only drawn up afterwards.

The district court put it this way: the margin scheme is a favourable exception, so the dealer must make it plausible that he meets the conditions. That can be done with a proper purchase statement or purchase invoice. The court of appeal upheld the ruling on 4 March 2025 (Court of Appeal Arnhem-Leeuwarden, ECLI:NL:GHARL:2025:1272).

Can you still prove afterwards that a car was a margin car?

In theory yes, in practice it is difficult. A missing purchase statement does not automatically mean the margin scheme no longer applies. You may also make it plausible in another way (Court of Appeal Arnhem-Leeuwarden, ECLI:NL:GHARL:2025:1272).

But annual accounts and ledger cards are not enough for that. They do not show from whom the cars were bought and whether that seller could deduct VAT, the court of appeal held. The dealer only had his books for 2014 and 2015 drawn up in 2020. That did not save him.

What does help is evidence you record at the time of purchase: the signed statement, a copy of the registration certificate, a bank payment to the named seller. What you do not record on the day of purchase you rarely manage to piece together later.

Why does the Belastingdienst pay so much attention to this paper trail?

Because VAT works through a chain of documents. In a normal sale, the VAT is on the seller's invoice and the Belastingdienst can check that invoice with both parties. Under the margin scheme that VAT invoice is missing. The purchase statement is then the only evidence that the previous owner did not deduct VAT (VAT Act, article 28b).

Research shows how strongly such a paper trail works. In two randomised experiments with more than 400,000 Chilean firms, an announced extra audit had less effect on sales that already had a paper trail to another business. That suggests the trail itself already discourages evasion (Pomeranz, 2015). The study is about Chile, not the car trade, but it explains why a complete file per car is the basis of every audit.

Sources

• VAT Implementing Decree 1968 (Uitvoeringsbeschikking omzetbelasting 1968), articles 4a and 31, in force from 1 April 2026. wetten.overheid.nl
• VAT Act 1968 (Wet op de omzetbelasting 1968), article 28b, in force from 1 January 2026. wetten.overheid.nl
• Belastingdienst, Administrative VAT obligations when trading in margin goods, accessed 22 October 2026. belastingdienst.nl
• Belastingdienst, Drawing up a purchase statement, accessed 22 October 2026. belastingdienst.nl
• Belastingdienst, Calculating VAT when you repair margin goods, accessed 22 October 2026. belastingdienst.nl
• Belastingdienst, How long must you keep your VAT records: 7 or 10 years?, accessed 22 October 2026. belastingdienst.nl
• District Court of Northern Netherlands, 1 June 2023, ECLI:NL:RBNNE:2023:2202. uitspraken.rechtspraak.nl
• Court of Appeal Arnhem-Leeuwarden, 4 March 2025, ECLI:NL:GHARL:2025:1272. uitspraken.rechtspraak.nl
• Pomeranz, D. (2015). No taxation without information: deterrence and self-enforcement in the value added tax. American Economic Review, 105(8), 2539-2569. doi.org