Overview
You must be authorised if you wish to hold unregistered vehicles.
Being authorised also allows a trader to avail of other benefits such as pre-inspection by the National Car Testing Service.
Authorisation of motor traders
You can apply to Revenue for authorisation to:
- manufacture
- distribute
- deal-in
- deliver
- store
- repair or modify
unregistered vehicles.
When not authorised by Revenue, you must follow the normal registration procedures.
To obtain an authorisation, you must apply to your local district and:
- show you intend to be actively engaged in the trade
- have suitable business premises
- be registered for Value-Added Tax (VAT)
- and
- have a current Tax Clearance Certificate.
Premises
There are two requirements in respect of the premises covered by the authorisation:
- the premises must be owned by the applicant, or rented, or legally leased by them
- and
- the premises must be one at which such business may legally be carried on. This excludes premises where the carrying on of the business is not permitted under planning laws.
VRT payment
If authorised, a Trader Account Number (TAN) is issued by Revenue. You will automatically be approved to use the non-deferred payment account or ‘FACT’ account. Details of this account and the conditions for deferred payment are available in the VRT Manual Section 10.
Revocation of an authorisation
Revenue can revoke an authorisation for reasonable cause and following reasonable notice.
The circumstances in which an authorisation may be revoked include:
- the holder is no longer actively engaged in one of the prescribed businesses, or never commenced the business
- the holder fails to produce a Tax Clearance Certificate when requested to do so
- or
- the holder does not keep the records of the business to the satisfaction of Revenue.
Where an authorisation is revoked, the business concerned can no longer hold, or deal in, unregistered vehicles.
Requirement to register
An authorised dealer who holds a new vehicle as stock-in-trade is not required to register the vehicle in their name. However, the dealer is obliged to ensure that the vehicle is registered before the customer takes delivery of it.
During a sale, the dealer collects the VRT from the customer and registers the vehicle in the customer’s name. This is done using the Revenue Online Service (ROS) or at an National Car Test (NCT) centre.
Once a vehicle is registered, it can then be supplied to the customer with registration plates fitted.
Only authorised motor dealers are entitled to hold unregistered vehicles. Where a non-authorised person obtains an unregistered vehicle, it must be registered in that person’s name and VRT paid.
Traders are required to keep all documents relating to both registered and unregistered vehicles for a period of six years. Periodic returns are also required electronically or in hard copy on the periodic stock statement Form VRT 17.
De-registration of vehicles
In exceptional circumstances, a vehicle may be de-registered and VRT repaid provided that the following conditions are met:
- The circumstances arise within seven working days of the date of registration
- The vehicle has not been licensed (road-tax has not been paid) for use in a public place
- and
- An application for de-registration is received within 21 days of the date of registration.
Applications for deletion of registration should be sent via MyEnquiries to the Central Vehicle Office.
The following information should be included with each application:
- full description of the circumstances giving rise to the application
- confirmation that the vehicle has not been licensed for use on a public road
- that the vehicle has not, and will not, be the subject of a repayment under any VRT repayment scheme
- whether the VRT was paid or deferred
- evidence from the owner’s insurance company of:
- the amount claimed and paid out, if any
- that no claim will be made or accepted
- or
- if a claim is made, that the amount to be paid out will exclude VRT.
Pre-inspection by National Car Testing Centre (NCTS)
Outline of system
Authorised dealers can make an appointment to:
- bring a vehicle(s) to an NCTS centre for a pre-inspection prior to having a buyer for the vehicle
- or
- arrange for NCTS staff to examine the vehicles at their premises.
Following the pre-inspection, the details of the vehicle are recorded on the Revenue Online System (ROS) pending sale of the vehicle. These details cannot be subsequently amended. When there is a buyer for the vehicle it can be registered on ROS.
If you do not have a ROS account, you cannot avail of this facility.
Pre-inspection at an NCTS centre
You must make an appointment with the NCTS and present the vehicle for inspection along with your Trader Account Number (TAN). The NCTS will:
- capture all the vehicle details (apart from the owner and payer details)
- and
- complete an enquiry with Revenue that will indicate the VRT payable on that date.
Pre-inspection by the NCTS at authorised premises
Alternatively, you can arrange to have the NCTS inspect the vehicle(s) at your premises for a fee. Details of this are available in the FAQ section of the NCTS website.
In both cases, the vehicle details are recorded on the ROS system to allow for registration at a future date.
Calculation of the VRT
The VRT payable is the amount calculated on the date of registration.
The Open Market Selling Price (OMSP), may increase between the time of the pre-inspection and the date of registration. This will mean that a higher amount of VRT will be due.
Value-Added Tax (VAT) is payable on a new means of transport and it will be included in the amount due at the pre-inspection stage. This is because the VAT number is not input until the point at which the vehicle is registered.
Selling the vehicle
When you have a buyer for the vehicle, you sign on to the ROS system and finalise the registration.
You pay the VRT by selecting the payment method (Deferred or FACT) which you opted for when applying for payment approval.
Pre-registration valuation of extras
An authorised dealer can make an application to have vehicle extras valued in advance of an appointment with the NCTS. This ensures that the valuation of extras is available at the time of registration.
The application should be sent via MyEnquiries to the Central Vehicle Office, in advance of the appointment.
Where multiple vehicles are listed on one purchase invoice, a copy of the invoice should accompany each form.
When the valuation of the extras has been completed, the approved form will be posted back to the applicant.
The original stamped form must be presented with the vehicle at registration.
Owner name and address
Introduction
The correct owner name and address information must be declared to Revenue at the time of registration of motor vehicles.
The name declared is the name that will appear on the Vehicle Registration Certificate (VRC). This is the person responsible in law for that vehicle.
There is a legal responsibility on dealers not to enter owner details that they know to be wrong or misleading.
Ownership details
The owner to be named at registration is:
- the person, or the legal entity by whom the vehicle is to be kept
- or
- if a vehicle is the subject of a hire-purchase agreement or a lease, the person or the legal entity named on the agreement or lease.
Legally accountable entity
This phrase includes:
- all businesses incorporated under the Companies Acts
- and
- other entities, for example, Local Authorities, trusts and suchlike.
It is not possible to give an exhaustive list of acceptable legal entities. The name under which the declared owner is registered for tax purposes should be acceptable.
‘Trading as’ or ‘t/a’ names
A ‘trading as’ or ‘t/a’ name is not acceptable as an owner as it is not a legal entity.
The trading name with ‘t/a’ may, however be entered on the declarations in addition to the legal entities name.
Joint names
Only one person can be declared as the owner of a vehicle. The declaration of ownership of vehicles in joint names is not acceptable.
Address
The address required is the address in the State at which the owner ordinarily resides at the time of registration.
This address:
- determines the county identifier on the registration plate
- determines the address to which the vehicle registration certificate will be posted
- and
- can also be used for legal purposes.
The declaration of some other address, for example a relative of the owner, is not permitted. In particular, ‘care of’ addresses are not to be used.