Invoicing foreign clients as an autónomo in Spain: ROI, reverse charge and the Modelo 349
Summary
- Two things decide what your invoice looks like: whether the client is a business or a private person, and whether they are inside or outside the EU.
- Services to a business in another EU country are taxed where that client is based, so you invoice without Spanish VAT and add the wording «inversión del sujeto pasivo» (reverse charge).
- To do that you need a NIF-IVA, which you get by joining the Registro de Operadores Intracomunitarios (ROI) through box 582 of the Modelo 036. The Agencia Tributaria can check the request and can refuse it.
- You only have a working intra-EU VAT number once it shows up in VIES, and you have to check your client’s number there too.
- The Modelo 349 is due in the first 20 calendar days after each period, with December and the fourth quarter due in the first 30 days of January.
- Spanish VAT still applies at 21% to most private customers in other EU countries, and to EU business clients whose VAT number you cannot validate.
Introduction
Invoicing foreign clients as an autónomo in Spain follows different rules from invoicing a client in Madrid or Valencia. The amount you charge may be the same, but the VAT line is not. Depending on who the client is and where they are, you may have to charge 21%, charge nothing, or charge nothing and also file an extra return.
The rules are not hard once you see the logic behind them. Spanish VAT law asks one question first: in which country is this service considered to take place? The answer decides everything else, including whether you need to be in the ROI, whether you file a Modelo 349, and which box of your Modelo 303 the income lands in.
This guide walks through each situation. It explains the rules as they stand for the 2026 tax year. It is general information, not tax advice, and your own case can differ.
Two questions decide every invoice you send
Before you type a single line on an invoice, answer these two questions about your client.
Is the client a business or a private person? A business means someone acting as an empresario o profesional, in Spain or abroad. A private person is anyone buying for themselves. The difference changes where the service is taxed.
Are they inside or outside the EU? Inside the EU, there is a system for passing the VAT over to your client. Outside the EU, there is not, because the other country’s rules take over.
A third factor sits underneath both: the type of service. Most freelance work (design, writing, development, consultancy, coaching) follows the general rules below. Some services have their own rule, such as work on a specific building, which is always taxed where the building is. If you are new to the vocabulary here, the Spanish tax glossary covers the terms.
Spanish VAT and the matching return, by type of client (2026)
| Your client | Spanish VAT on the invoice? | Where it is reported |
|---|---|---|
| Business in another EU country, VAT number valid in VIES | No, reverse charge applies | Modelo 349 (key S) and box 59 of the Modelo 303 |
| Business in another EU country, VAT number you cannot validate | Yes, 21% | Modelo 303, as a normal Spanish sale |
| Private person in another EU country, normal service | Yes, 21% | Modelo 303, as a normal Spanish sale |
| Private person in another EU country, digital service above the 10,000 euro limit | No Spanish VAT, you charge the client’s country rate | One Stop Shop return (Modelo 369), and box 123 of the Modelo 303 |
| Business outside the EU | No | Box 120 of the Modelo 303 |
| Private person outside the EU, listed services such as consultancy, advertising, legal work or translation | No | Box 120 of the Modelo 303 |
| Private person outside the EU, any other service | Yes, 21% | Modelo 303, as a normal Spanish sale |
How do you invoice a business client in another EU country?
You invoice without Spanish VAT. For most freelance services, the place of supply is where the client has their business, so the VAT belongs to their country and not to Spain. Your client declares it themselves through the reverse charge. Your invoice must show both VAT numbers and carry the wording «inversión del sujeto pasivo».
In practice, the invoice looks like a normal one with two changes. The VAT line reads 0, and you add a sentence explaining why.
The legal basis is the general rule that a service is taxed where the business client is established. That rule applies whatever country you supply from. So a copywriter in Alicante billing an agency in Berlin is, for VAT purposes, supplying in Germany.
Three things need to be on the invoice:
- Your own Spanish VAT number with the ES prefix, for example ESX1234567Z.
- Your client’s VAT number from their own member state.
- The mention «inversión del sujeto pasivo», which you can repeat in English as “reverse charge” for clarity. That wording is attached to invoices where the recipient is the person liable for the tax, and your invoice follows the Spanish invoicing rules because you supply from Spain, even though the service itself is located in your client’s country.
Leaving the mention off does not change who owes the VAT, but it does make the invoice incorrect, and clients often send it back. Writing it in both languages costs nothing.
What is the ROI and how do you register for it?
The ROI is the Registro de Operadores Intracomunitarios, the Spanish list of businesses cleared to trade with other EU countries. Joining it gives you a NIF-IVA: your usual tax number with ES in front. You apply through the Modelo 036. The Agencia Tributaria can check the application and can turn it down.
You need the NIF-IVA whenever you supply services that are taxed in another member state and your client is the one who pays the VAT there. The same applies in reverse, when you buy services from an EU supplier and have to self-assess Spanish VAT on them.
To apply, you file a census declaration to join the ROI: tick box 582 on the Modelo 036 and put the expected date of your first intra-EU operation in box 584. You can file it online with a digital certificate or Cl@ve. If you are still setting up your activity, you can request the ROI in the same Modelo 036 you use for registering as an autónomo.
Then comes the part people do not expect. This is not an automatic registration. The tax office may contact you to confirm that you really carry out the activity, and it can refuse the number in the cases set out in the general tax regulation. If it has not decided within three months, you may treat the request as refused.
Until you appear in VIES, you do not yet have a usable intra-EU VAT number. An invoice sent before that point, with no Spanish VAT on it, is a problem waiting to happen. Many freelancers apply for the ROI well before their first foreign invoice for exactly this reason. Timelines vary by case, and nobody can promise you a date.
Why do you have to check your client’s VAT number in VIES?
Because the reverse charge only works if your client is really a registered business in their country. VIES is the European Commission tool that confirms this. It is a search engine rather than a database: it queries each national VAT register live. If the number does not come back valid, you cannot safely invoice without Spanish VAT.
Treating a client as a business is allowed when they have given you their VAT number and you have confirmed that the number is valid and matches their name and address. That confirmation is your evidence, so save it. A screenshot or the consultation number with the date is enough.
An invalid result can mean several things: the number does not exist, the business has a national VAT number but has never been enabled for intra-EU trade, or their registration is still being processed. Updates also take time to reach VIES, so a brand new registration may not show immediately.
If you cannot validate the number, do not guess. Ask the client to check with their own tax office. Until they come back with a working number, the safe treatment is to charge Spanish VAT at the standard rate of 21%. You can always issue a corrective invoice later.
What is the Modelo 349 and when do you file it?
The Modelo 349 is an informative return that lists your intra-EU operations. You pay nothing with it. It exists so tax authorities across the EU can match your zero VAT invoice against what your client declared. Any business doing intra-EU operations files it, whatever VAT regime they are in, and you skip any period with no operations.
Each client appears with their VAT number, the total for the period, and an operation key. Services you provide go under key S. Key I covers intra-Community services you receive that are located in the Spanish VAT territory, which are the ones you account for yourself.
The filing deadlines work like this:
- Monthly is the default. You file in the first 20 calendar days of the following month. The July return can go in during August or in the first 20 days of September.
- December is different. It is due in the first 30 calendar days of January.
- Quarterly is allowed if your total intra-EU supplies of goods and services stay at or below 50,000 euros, VAT excluded, in that quarter and in each of the four previous quarters. Quarterly returns follow the same 20 day window, and the fourth quarter is due in the first 30 days of January.
- Crossing the limit mid-quarter moves you to monthly. If you pass 50,000 euros at the end of a month inside a quarter, you file within the next 20 days for the months of that quarter so far.
Most freelancers stay well under 50,000 euros and file quarterly. Worth noting: the 349 is separate from your VAT return, has its own deadline, and is easy to forget. The Spanish tax calendar sets out the full year.
Where does this income go in your Modelo 303?
It still goes in, even though you charged no VAT. Intra-EU services belong in box 59, “entregas intracomunitarias de bienes y servicios”. Services to clients outside the EU, and other services not taxed in Spain under the place of supply rules, go in box 120. Neither adds output VAT, and your input VAT stays deductible.
That last point matters. Invoicing without Spanish VAT does not cost you your deductions. You keep claiming the VAT on your deductible expenses for autónomos. The result of each return is still output VAT minus deductible input VAT, and invoices without Spanish VAT add nothing on the output side, so what the balance comes to depends on your own figures.
The Modelo 303 deadlines are the 1st to the 20th of April, July and October, and the 1st to the 30th of January for the fourth quarter. Those dates sit alongside your income tax instalments, covered in the guide to quarterly returns in Spain. Foreign income counts towards your income tax the same way domestic income does.
How do you invoice clients outside the EU and private clients in the EU?
Outside the EU, business clients are simple: no Spanish VAT, no Modelo 349, box 120 of the Modelo 303. Private clients are where people slip. A private customer in another EU country usually pays Spanish VAT at 21%, because the service is taxed where you are. There are two exceptions worth knowing, set out below.
Business clients outside the EU
The same general rule applies as inside the EU: the service is taxed where your client is. So an invoice to a company in the United States, Brazil or Switzerland carries no Spanish VAT. There is no reverse charge mention to add, because the EU mechanism does not reach that far. You do need proof that the client is genuinely a business, such as a tax certificate or their national business registration number, and the Modelo 349 does not apply.
Private clients in another EU country
Here the general rule flips. When the client is not a business, the service is taxed where the supplier is, which means Spain. You charge 21%, you report it as a normal Spanish sale, and the ROI plays no part. A Dutch customer buying a one to one coaching session from you is, for VAT, no different from a customer in Seville.
Digital services to private clients
Electronically supplied services, telecoms and broadcasting follow their own rule when the customer is a private person: they are taxed in the customer’s country. There is a relief if your total cross-border sales of this kind stayed at or below 10,000 euros, VAT excluded, in the previous calendar year and you supply from Spain only, in which case you keep charging Spanish VAT. The relief also stops the moment you go over 10,000 euros during the current year: from that point the service is taxed in the customer’s country, with no wait for the next 1 January. Above the limit you charge the customer’s national rate and declare it through the One Stop Shop, using the Modelo 369, and you report the same turnover in box 123 of your Modelo 303.
If your mix of clients covers several of these boxes at once, it is worth having someone look at the whole picture rather than invoice by invoice. Tytle helps autónomos in Spain understand which rules apply to their situation and prepare the returns that go with them.
Frequently asked questions
You need it whenever you supply services that are taxed in another member state and your client is the one who accounts for the VAT there. That covers most freelance work billed to an EU business. Without a NIF-IVA you cannot apply the reverse charge, so the correct treatment is to charge Spanish VAT at 21%. You request the registration on the Modelo 036 by ticking box 582 and giving the expected date of your first intra-EU operation in box 584. The number only works once it appears in VIES. If your activity is entirely VAT exempt in Spain, the rules on assigning a NIF-IVA may exclude you, so check your own situation.
For an EU business client, the invoice needs your Spanish VAT number with the ES prefix, your client’s VAT number from their member state, and the mention «inversión del sujeto pasivo». You can add “reverse charge” in English next to it, which many clients prefer. Keep the VAT line visible and set it to zero rather than deleting it. For a client outside the EU, no reverse charge mention is required, because that mechanism is an EU one. Everything else on the invoice stays the same: date, sequential number, your details, the client’s details, a clear description of the service, and the amount.
There is no fixed answer, and nobody can promise you a date. The Agencia Tributaria may run a census check on your application, which can mean a request for documents about your activity, your clients or your premises. Responding quickly helps. The rule that gives you certainty is the three month one: if the tax office has not decided within three months of your request, you may treat the assignment of the number as refused, which opens the way to appeal. Until your number shows as valid in VIES, treat yourself as not yet registered and plan your invoicing around that.
Do not issue the invoice without VAT. An invalid result can mean the number does not exist, the business has never been enabled for intra-EU trade, or the registration is still being processed. Ask the client to confirm their status with their own tax authority and to send you the working number. In the meantime, the safe treatment is Spanish VAT at 21%. If they come back with a valid number later, you can issue a corrective invoice. Always keep evidence of the check you did, with the date and the result, because that evidence is what supports your treatment if the return is reviewed.
No. The Modelo 349 is not filed for periods with no intra-EU operations. If you invoiced one German client in March and nobody else that year, you file for that period only. This is different from the Modelo 303, which you file every quarter once you are registered for VAT, even when the result is zero. One thing to watch: services you receive from EU suppliers also belong in the 349, under key I. Subscriptions to EU based software or services can quietly create a filing obligation in a period when you invoiced no EU clients at all.
Yes. Charging no VAT on a service taxed in another country does not remove your right to deduct the VAT you paid on business purchases. You go on claiming it in the usual boxes of your Modelo 303. Each return is still output VAT minus deductible input VAT, and these invoices add nothing on the output side while your input VAT keeps counting, so the balance follows your own figures. Where a return does end in a credit, quarterly filers normally ask for the refund in the fourth quarter return. The general deduction rules still apply, so the expense has to be genuinely linked to your activity and properly documented.
If the client is a business, no. The service is taxed where the client is established, so it falls outside Spanish VAT, and it goes in box 120 of your Modelo 303. You do not file a Modelo 349, because that return only covers EU operations. Keep evidence that the client is a business, such as a tax certificate from their authorities or a national business number, plus a reasonable check of it. If the client is a private person, it depends on the service. Consultancy, advertising, legal work, data processing and translation are not taxed in Spain. Many other services are, at 21%.
Yes. VAT and income tax are separate systems. The fact that an invoice carries no Spanish VAT says nothing about income tax. If you are tax resident in Spain, your worldwide professional income is part of your IRPF base, including everything you billed abroad. It feeds your quarterly instalments and your annual return in the same way as Spanish income. Where foreign tax has been withheld at source, a double tax treaty may decide which country taxes what, and how relief works. That is situation specific, so it is worth checking the treaty with the country concerned.
They are part of Spain but sit outside the territory where Spanish VAT applies, so intra-EU VAT rules do not cover them. A service to a business established in the Canary Islands is not subject to Spanish VAT, and it does not go on the Modelo 349. There is a twist for private customers: the list of services that escape Spanish VAT when the customer is a private person outside the EU specifically excludes customers in the Canary Islands, Ceuta and Melilla. So a consultancy invoice to a private individual in Las Palmas does carry Spanish VAT, while the same invoice to a private individual in Argentina does not.
It affects most autónomos who invoice with software, but not yet. The start dates have been pushed back twice. Under Real Decreto-ley 15/2025, of 2 December 2025, companies that pay corporate income tax have until 1 January 2027, and other taxpayers, self-employed people included, until 1 July 2027. The Ministry of Finance announced in October 2026 that it intends to move the remaining obligations to October 2028, but nothing has been published in the BOE, so the 2027 dates are the ones in force. The rules govern how invoices are generated and stored, not the VAT treatment described above, so your intra-EU obligations stay the same either way.
This content is for informational purposes only and does not constitute tax, legal, or financial advice. Tax laws change frequently and vary by jurisdiction. Consult a qualified tax professional for advice specific to your situation.
