UK vehicle V5 with Northern Ireland Address

Using an Address in Northern Ireland to Avoid Customs and VAT when bringing a UK vehicle to Spain

In the wake of Brexit and the introduction of the Windsor Framework, many UK vehicle owners have questions about the legalities of moving cars from Great Britain to Spain via Northern Ireland.

There is a claim that there is a “legal loophole” to route vehicles through Northern Ireland (NI) to avoid paying customs duty and VAT in Spain, even when the owner never lived in or used the vehicle in Northern Ireland.

So is routing a GB vehicle through Northern Ireland to avoid import taxes in Spain legal?  In this article, we clarify how the Windsor Framework applies to vehicle movements, what is genuinely legal, and what could land you in trouble.


🚗 What Is the Windsor Framework?

The Windsor Framework, agreed in 2023, is the updated set of rules that governs trade between Great Britain (England, Scotland, Wales) and Northern Ireland, while keeping Northern Ireland aligned with certain EU single market regulations.

For vehicle movements, this means:

  • No customs duties or checks for genuine personal use vehicles moved from GB to NI.

  • But: Northern Ireland remains in the EU customs territory for goods that may move onward to the EU (e.g. to Spain).

To import a vehicle from the UK mainland to Northern Ireland under the Windsor Framework, you need to be authorized under the UK Internal Market Scheme (UKIMS) and potentially utilize the Simplified Processes for Internal Market Movements. This framework streamlines the process for eligible goods moving from Great Britain to Northern Ireland, allowing for a reduced declaration process.

Crucially, this allows you to declare goods as “not at risk” of entering the EU, meaning you won’t pay EU duties if the vehicle is staying in Northern Ireland or will be moved back to Great Britain.  Goods declared as “not at risk” are not subject to the full customs procedures, and will avoid customs duty and VAT.  If the vehicle in the future is then taken to an EU country, such as Spain, it is treated originating in the EU as it is assumed customs was taken care of when the vehicle was moved from GB to NI.  This is what appears to be being distorted.

If a GB vehicle (from England, Scotland, or Wales) is moved to Northern Ireland (NI) and is “at risk” under the Windsor Framework, i.e. it is not going to be used in NI but is to be taken to Spain, then EU customs rules apply, and the vehicle is effectively treated as if it were being imported into the EU customs territory.

  • The vehicle must go through the EU customs import procedure at entry into NI (because NI aligns with the EU Customs Code).

  • A customs declaration must be made via the UK Trader Support Service (TSS) or an agent.

  • The vehicle is automatically deemed “at risk of entering the EU”.

  • This triggers EU tariffs and import customs and VAT (10% and 20%) just as if the vehicle were entering the EU directly.


Clearly if an indivdual is taking their car from GB to NI where they have an address and will be using it, then “not at risk” would be applicable.  However, if the intent is to simply route the car through Northern Ireland, not take it there or use it there, and instead take it Spain, then clearly “not at risk” cannot truthfully or legitimately be declared.

✅Legitimate Use Case: The Spanish Perspective

🔹 Current Practice in Spain:

  • Spanish customs authorities are (at least for now) applying a blanket exemption from import duty and VAT to vehicles declared as originating from Northern Ireland, regardless of the owner’s residence history or whether the vehicle was genuinely located in NI.

  • In effect, if a vehicle is registered in NI (or shows NI as the last place of registration), Spanish customs are processing it as exempt, based on the assumption that:

    • It is moving from within the EU customs territory (under the Northern Ireland Protocol), and

    • It is therefore not subject to the same treatment as goods coming from Great Britain (England, Scotland, Wales), which are now “third countries” under EU law.

Let’s consider a legitimate scenario under the Windsor Framework and EU import rules:

Example:

  • You live in England and are relocating to Northern Ireland, or

  • The vehicle owner lives in Northern Ireland or can prove genuine use/residence there.
  • The personal vehicle is physically taken from GB to NI and actually used there.

  • Later, you relocate again, this time to Spain, or you just decide to take the vehicle to use in Spain.

  • The vehicle is moved to Spain and declared as coming from NI.

  • Spanish customs, under current practice, treat this as exempt from duty and VAT.

✅ This is legal as the vehicle and it’s origin is truthfully declared and the authorities apply their rules for exemptions accordingly.


🛑 Fraudulent Use Case: Fake NI Routing to Evade Tax

Here’s what’s not legal:

Example:

  • You live or lived in England and own a GB registered car

  • A false registration address is used to create the appearance that the vehicle is from NI.
  • The vehicle never physically enters Northern Ireland.

  • The car is shipped or driven directly to Spain, and presented at registration as having originated in Northern Ireland.

  • Spanish authorities mistakenly exempt the car based on documentation that is intentionally misleading.

Even if the exemption is applied, if the basis for that treatment is a false representation, it remains fraudulent — and:

  • The vehicle owner is liable,

  • Any facilitators (e.g. vehicle regitration agents) are criminally exposed,

  • Spanish authorities may later pursue recovery of tax plus penalties.

Summary:

❌ This is fraud.

  • The Windsor Framework allows genuine cross-border movement, not paper-based fraud.

  • Falsely declaring origin, destination or residence for tax avoidance is illegal under:

    • Spanish Penal Code (Article 305 – Tax Fraud),

    • EU Customs Code, and

    • UK Fraud Act 2006, if part of the deception occurred in the UK.

Read more about the legal implications.


💼 Key Requirements for Lawful Movement via NI

To legally use Northern Ireland as a step in the import chain, the vehicle must:

  1. Be physically moved to Northern Ireland.
  2. Be registered or used by a person who has a real residence in NI.
  3. Not be moved to the EU (e.g. Spain) with the intent to evade customs duties or VAT.
  4. Be declared truthfully to the Spanish authorities, along with truthful supporting documents.

If you cannot prove actual use or residence in NI, the route is not valid, and any attempt to claim tax exemption is likely to be considered fraudulent.


📌 Final Clarification

So while it’s true that Spanish customs are applying a blanket exemption, to UK vehicles that are registered to a Northern Ireland address, this only holds up legally if the NI origin is true.

  • If the origin is falsified, the exemption has been wrongly applied, and the parties involved may be prosecuted even after the fact.

  • Spanish tax authorities (Agencia Tributaria) can open a retrospective investigation if there is evidence of false origin declarations — leading to reassessment, fines, and criminal charges.

The Windsor Framework for goods moving from Great Britain to Northern Ireland, does not create a tax loophole for avoiding Spanish import duties. It facilitates legitimate trade and personal movement between parts of the UK—but abusing it evade import duty and VAT when importing a vehicle from Great Britain to Spain could lead to:

  • The vehicle being seized in Spain,

  • Significant fines and backdated VAT/duty,

  • Criminal charges for fraud,

  • Possible investigation in the UK and EU.

If you’re importing a car to Spain and genuinely lived in Northern Ireland, you may have a legitimate route to lower taxes—but it must be truthful, documented, and compliant with both UK and Spanish law.

ITV Inspeccion Tecnica de Vehiculos

The ITV – Inspección Técnica de Vehículos – Spain’s Vehicle Technical Inspection

In Spain, the periodic road worthiness inspection, is the ITV. (Inspeccion Tecnica de Vehiculos – Vehicle Technical Inspection).  Like the UK MoT test, it’s mandatory for all road going vehicles, and driving without a valid ITV can result in fines.

When Does The ITV have to be done?

The frequency of the ITV test depends on the age and type of vehicle.  New cars are first tested after 4 years and must be inspected every 2 years thereafter, until they reach 10 years of age. Any car over 10 years of age has to be tested annually.

Motorcycles, mopeds and quad bikes are first tested after 5 years, after which the test is due every 2 years. Caravans are first tested at 6 years, after which the test is due every 2 years.

If a vehicle has been involved in a serious accident, it also has to undergo an ITV assessment after being repaired, to confirm its road worthiness.

Registering a UK car in Spain

Register a UK Car in Spain

The UK is no longer in the EU and the process and costs to register a UK car in Spain are a lot more than they were before Brexit.

This is because UK cars now are now treated as vehicles from third countries and must clear customs, have import duty and VAT paid, or get a waiver if your car qualifies for customs exemption.

The process you follow will depend on your situation, as will the cost.  You’ll need to budget for costs of around €1,500 with taxes as applicable on top.

Passing the ITV in Spaiin

Passing the ITV

In Spain all vehicles are subject to regular safety checks through a road worthiness test, known as the ITV, Inspecciòn Tècnica de Vehiculos, – Vehicle Technical Inspection.

New cars are tested after 4 years, and are then required to be inspected every 2 years until the car is 10 years old.

New mopeds, quads, and motorcycles are tested after 5 years, and then every 2 years until they reach 10 years.

Any vehicle over 10 years is required to be inspected and tested every year.

All vehicles being imported to Spain are also subject to an initial special inspection before the vehicle can be registered in Spain.  This inspection has a few more checks, as along with roadworthiness, the technicians are checking that the vehicle conforms with standards.

Before undergoing the technical inspection of your vehicle, you should carry out some basic checks that can prevent the result from being unfavorable.  The list below covers the standard test and as well as the extended import inspection.

Historic licence plates for classic cars in Spain

Historic Number Plates for Classic Cars in Spain

Registering Classic Cars in Spain

The process of assigning a registration number to a Classic Car in Spain is more or less the same as that for a normal car.  However the car will have to go through more vigorous checks before it can be passed.  There is no differentiation in regard to age of vehicle and the registration number issued.  So a 50 year old classic Ferrari brought to Spain from another country, and a brand new Nissan Micra, could end up with consecutively numbered plates.

This is quite different to the UK for example, where vehicle registration numbers have a year marker, so you can know the cars are from the number plate.  Spanish vehicle registration numbers have no age identifier.

From a Classic Car perspective, this means that, if you’re bringing your pride and joy 1964 Mercedes SL to Spain, when you register it, you will end up with a registration number that doesn’t fit with the age of the car.  The registration will be just like any other regular new cars registered at the same time. Not great for prestige.

Exchanging a UK or EU driving licence for a Spanish one

Exchanging Your UK or EU Driving Licence for a Spanish Driving Licence

If you hold a UK or EU driving licence from outside of Spain are expected to exchange it for a Spanish one when you become resident in Spain.

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Exchanging your licence

If you change your residence to another EU country, you don’t usually have to change your driving licence. You can use your current licence as long as it remains valid.

If you wish, you can voluntarily exchange your licence for an equivalent one in your new country of residence.

You will have to prove that you are a resident of that country and that you meet the conditions for having a driving licence (e.g. you have reached the minimum age, your state of health permits you to drive, etc.).

Before the authorities exchange your driving licence, they will contact the authorities in your previous country of residence to check that your driving licence has not been restricted, suspended or withdrawn.

Obligatory exchange

When living abroad, you will have to exchange your driving licence for a local one:

  • if your licence is lost, stolen or damaged
  • after 2 years of usual residence, if you have a driving licence valid for life (only if required by the country where you live)
  • if you commit a traffic offence in the country where you live
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Many non-EU countries, UK included, have a reciprocal agreement with Spain to exchange licenses.  Where this is the case, you follow the same procedure as a EU citizen when you become resident and exchange your licence.   The only difference is, driving licences from non-EU countries are only valid to use for 6 months from the date of getting residency, so the exchange of licence needs to be done within that time.

Register a vehicle form a non-EU country in Spain

Import and Register a Car From a Non-EU Country in Spain

The are quite a few steps and costs involved to import and register and car from a non-EU country in Spain.

First and foremost EU conformity, import and registration costs must be taken into account as these can make the import and registration in Spain impossible or too expensive to be worth while.

This said, under EU rules if you are moving from a non-EU country to live in an EU country, such as Spain, you can bring your possessions including cars, and avoid paying the costly duties and taxes and having to pay for expensive EU conformity certification.

These transfer of residence rules give you up to12 months form the date you get your residency to import your car and avoid paying customs and VAT.  However you only have 60 days from the date you take up residency, to register your car and avoid registration tax (if it applies).  

Importing a High Value Car from the UK to Spain Post Brexit

Importing a high value car from the UK in Spain post Brexit, now comes with added costs.  As the UK is no longer in the EU and the standard process to import and register a UK car in Spain now involves customs.

This means on top of the registration tax which in most cases will be 17% of the vehicle value, 10% customs duty and 21% VAT will apply, unless you can find away around it.

Paying nearly £50k to register a £100k motor is simply not a consideration.  There are however various ways these huge costs can be avoided, bringing the cost of importing and registering high value cars in Spain down to a few thousand Euros, rather than tens of thousands.

Vehicle Taxes Spain

Vehicle Tax in Spain

When you own or register a vehicle in Spain, you almost always have to pay some form of vehicle tax.  The type and amount that applies depends on the vehicle.

Local Vehicle Tax

IVTM Impuesto sobre Vehículos de Tracción Mecánica is the Spanish equivalent of what we refer to in the UK as road tax.  Almost all vehicles driven on public roads in Spain, are subject to this tax, which is administered and collected locally by the Town Hall.

The tax is set by the municipal authorities, and varies from area to the next. IVTM is paid to the local authority and can be paid in person at the relevant Town Hall office (Ayuntamiento), at a bank or by direct debit.

Vehicle Tax When Registering a Vehicle in Spain

When you register a vehicle in Spain, either new or used, in all cases locally collected road tax‘ – IVTM (Impuesto Sobre Vehículos de Tracción Mecánica), must be up to date.

There are 3 main circumstances and taxes that apply when registering a vehicle in Spain. These are:

  • Purchase of a new vehicle
  • Buying a second hand vehicle or changing ownership
  • Importing or registering of a foreign vehicle

Tax – New Vehicle Purchase

New vehicle purchases in Spain are subject to IVA (Impuesto sobre el Valor Añadido), Spanish VAT – currently 21% of purchase value.

In addition, when a vehicle is first registered in Spain, it may be subject to an additional registration tax.

This vehicle tax is based on the new value of the vehicle and it’s CO2 emissions.  Vehicles with CO2 emissions below 120g/km are exempt from the tax, and the rate increases with the level of emissions as follows:

  • 121g/km – 159g/km = 4.75%
  • 160g/km – 199g/km = 9.75%
  • 200g/km or higher = 16.75%