🚨 Accountable does not currently support the VAT margin scheme.
If your business consists of buying and selling used vehicles (or other second-hand goods, works of art, collectors' items, antiques) under this scheme, Accountable is not the right tool for you. We recommend working with a traditional accountant who can handle the specific obligations of this regime.
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This article explains what the VAT margin scheme is, who can use it in Belgium, and what you need to know if you (or one of your clients) operates under it.
💡 What is the VAT margin scheme?
The margin scheme (régime de la marge bénéficiaire in French, btw-margeregeling in Dutch) is a special VAT regime defined in article 58, §4 of the Belgian VAT Code.
Under this regime, VAT is calculated only on your profit margin (the difference between what you bought a good for and what you sold it for), not on the full sale price.
Why does this regime exist? When you buy a second-hand good from someone who can't charge VAT (for example, a private individual selling their old car), and then resell it, the normal VAT rules would force you to charge VAT on the full sale price, even though VAT was already paid once when the good was new. The margin scheme is designed to avoid this double taxation.
🧮 How is VAT calculated on the margin?
VAT is included in the margin. At the standard 21% rate, that means 21/121 of the margin.
Example with a used car
Purchase price: €10,000
Sale price: €13,000
Margin (VAT included): €3,000
Taxable base: €3,000 × 100/121 = €2,479.34
VAT due: €3,000 × 21/121 = €520.66
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📄 What does the invoice look like?
An invoice issued under the margin scheme has two key characteristics:
VAT is not shown separately. The buyer sees a total price, VAT included, and cannot tell what your margin is.
The invoice must include the appropriate margin-scheme mention, depending on the type of good:
Type of good
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Mandatory mention
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Second-hand goods (e.g. used cars)
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FR: « Régime particulier - Biens d'occasion »
NL: « Bijzondere regeling - Gebruikte goederen »
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Works of art
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FR: « Régime particulier - Objets d'art »
NL: « Bijzondere regeling - Kunstvoorwerpen »
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Collectors' items and antiques
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FR: « Régime particulier - Objets de collection et d'antiquité »
NL: « Bijzondere regeling - Voorwerpen voor verzamelingen en antiquiteiten »
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The FPS Finance also commonly refers to the alternative formulation: « Livraison soumise au régime particulier d'imposition de la marge bénéficiaire. TVA non déductible. »
🛒 What if you buy something under the margin scheme?
If you buy a good (for example, a car for your business) and the invoice shows a margin-scheme mention without a separate VAT line, here's what you need to know:
You cannot deduct any VAT on this purchase, even if you are VAT-registered. There is no separately invoiced VAT to recover.
For cars specifically: you cannot apply the administrative tolerance that allows VAT to be calculated on only 50% of the price. This tolerance only exists for cars purchased under the normal VAT regime.
💡 Good news on related costs: VAT on maintenance, repairs and fuel for a car bought under the margin scheme remains deductible according to the normal rules (typically up to 50% for mixed-use cars). Only the VAT on the purchase itself is lost.
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✅ Who can use the margin scheme as a seller?
Three conditions must all be met:
1. The type of good qualifies
Eligible:
Second-hand goods (most commonly used vehicles)
Used cars, motorcycles, caravans, boats, aircraft
Works of art, collectors' items, antiques
Not eligible:
New goods
Precious metals, precious stones, pearls
Fully renovated goods (simple repair is fine, full restoration is not)
Goods so transformed that they can no longer be identified with their original state
Goods consumed by first use, or non-reusable scrap
2. You bought the good without deductible VAT
The good must come from one of these suppliers:
A private individual (the most common case for used cars)
A VAT-exempt business under art. 44, §2, 13° CTVA (for example, a clinic selling medical equipment used only for its exempt activity)
A small business under the franchise scheme (art. 56, §2 CTVA), selling an investment good
Another professional reseller who already applied the margin scheme on that sale
⚠️ If the supplier charged VAT on the purchase invoice and you could have deducted it, the margin scheme cannot apply to your resale. You must then apply the normal VAT regime (VAT on the full sale price, typically 21% for cars but depending on the applicable rate for the good).
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3. You are a professional reseller
You must buy and sell these goods as part of your regular economic activity, not just once in a while. A freelancer selling their old laptop or business car at the end of its life is not a professional reseller and does not need the margin scheme — they sell under the normal regime.
📋 What are your obligations under the margin scheme?
If you operate under the margin scheme, you must:
Register your activity correctly at the Belgian Crossroads Bank for Enterprises (BCE/KBO) with the appropriate NACEBEL code (for example, 45.112 for used-car dealers), and with the FPS Finance via the standard 604A/604B forms.
Issue a bordereau d'achat (purchase slip) to your supplier when buying the good, unless they issue you an invoice. The bordereau must include the supplier's identification, a description of the good (for vehicles: brand, model, chassis number, registration), the price, and a signed declaration from the supplier confirming they could not deduct VAT.
Keep two registers: a purchase register (every good you buy under the scheme) and a comparison register (linking each purchase to its corresponding sale).
Track each item individually, not in bulk.
Keep separate accounting for your margin-scheme sales, either through a dedicated ledger or distinct columns in your invoice and receipts journals.
Be able to prove to a VAT inspector that your supplier qualifies under one of the four categories above.
⚠️ What happens if you apply the margin scheme incorrectly?
This is the part to take seriously. If a VAT inspection requalifies your margin-scheme sales into normal-regime sales (because the proof is missing, the registers are incomplete, the supplier didn't actually qualify, etc.), the consequences add up quickly.
Worked example, using the same car (€13,000 sale, €10,000 purchase, 2 years before the audit):
Cost item
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Amount
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Supplementary VAT owed (21% on €13,000 minus what you already declared)
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~€1,736
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Late-payment interest (2026 rate: 8% per year, over 2 years)
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~€278
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Administrative fine (typical first infraction: 10% of the VAT eluded)
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~€174
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Total exposure per car
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~€2,188
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For a dealer selling dozens of cars per year, this can quickly add up to a five- or six-figure exposure on an otherwise legitimate business that just used the wrong documentation.
💡 The late-payment interest rate changes each year. Always check the current rate on the FPS Finance Payment page before estimating an exact amount.
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🚫 Why isn't Accountable suitable for the margin scheme?
Accountable currently does not support the VAT margin scheme. Concretely, this means our invoicing and VAT engine cannot:
Create invoices without separate VAT lines
Calculate VAT on the margin (21/121 of the difference) instead of on the full price
Add the appropriate margin-scheme mention as a structured invoice element
Maintain the required separate accounting and comparison registers
Track individualised items (per chassis number, for example) across purchase and sale
If you try to process margin-scheme sales through Accountable as if they were standard VAT sales, the VAT declarations Accountable produces will be incorrect, and you will be exposed to significant risk at your next VAT inspection.
✅ What we recommend
If your activity involves the margin scheme as a seller (most commonly: used-car dealing), please work with a traditional accountant who can handle the bordereau d'achat, the registers, the comparison ledger, and the specific VAT calculations this regime requires.
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ℹ️ Buying under the margin scheme is fine
If you only buy a car or other second-hand good under the margin scheme (as a buyer, not as a seller in this regime), you can use Accountable normally. Just encode the expense without a deductible VAT amount, which our app already supports for VAT-exempt expenses.
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Still have questions or unsure whether this applies to your situation? Reach out to us via the chat or email support@accountable.eu and we'll help you figure out the right next step. 😊