Invoice an EU Client: VAT, ROI and Reverse Charge

If you want to invoice an EU client from Spain without charging the wrong VAT, you need to follow a short sequence: verify the client’s VAT number, check that you are registered in the right census, write the invoice with the reverse charge wording and report the operation in the right return. Done correctly, the invoice has no Spanish VAT and the client accounts for VAT in its own country.

The short answer: when you provide services to a business established in another EU country and it gives you a valid EU VAT number, the service is generally taxed where the client is established. You issue an invoice without VAT, mention the reverse charge, show both VAT numbers, be registered in the ROI and report the operation on modelo 349. If the client is a private person, the rules are different and Spanish VAT often applies.

VAT rules have exceptions (real estate services, events, restaurants, passenger transport and others) and thresholds change. This is general information for freelancers resident in mainland Spain, not tax advice. Check the current rules with the Agencia Tributaria or a gestor.

Key takeaways: invoice an EU client

To invoice an EU client without Spanish VAT, the client must be a business with a valid EU VAT number.
Validate both VAT numbers in VIES before you issue the invoice and keep a screenshot.
Your invoice should say that the reverse charge applies and cite the legal basis.
You normally need to be registered in the ROI and file modelo 349 for these operations.
Private persons in the EU are treated differently: Spanish VAT usually applies, with special rules for digital services.

In this guide

When can you invoice an EU client without VAT?

For services between businesses in the EU, the general rule is that the place of supply is where the customer is established. If the client is a business in Germany, France or Italy, the service is taxed there, not in Spain. The client reports and pays the VAT through the reverse charge mechanism, so you do not charge it.

Three conditions must be met at the same time:

The client is a business or professional acting as such, not a private consumer.
The client is established in another EU Member State and has a valid EU VAT number.
The service is covered by the general rule. Some services, such as those related to real estate or to events and admissions, follow special place-of-supply rules.

If one of these conditions fails, you may have to charge Spanish VAT. The wider context is explained in how to invoice a foreign company as a freelancer in Spain.

Step 1: validate the client’s VAT number in VIES

Before you invoice an EU client, check the client’s VAT number in the VIES system of the European Commission. It confirms whether the number is active for intra-EU operations.

Enter the country code and the number exactly as the client provided them.
Save the result (a screenshot or the consultation confirmation), because it is your evidence if the tax agency asks why you did not charge VAT.
If the number is not valid, ask the client for the correct one. Without a valid number you may have to charge VAT.

Your own Spanish VAT number should also appear as active in VIES. If it does not, you are probably not registered in the ROI yet.

Step 2: register in the ROI before you invoice an EU client

In Spain, businesses that supply services to other EU businesses without VAT normally need to be registered in the Registro de Operadores Intracomunitarios (ROI). You request it through the census declaration (modelo 036) with the Agencia Tributaria. Once registered, your Spanish tax number works as an EU VAT number with the prefix «ES».

Request the registration before your first invoice, because it can take some time to be processed.
Check in VIES that your number now appears as valid.
If you stop making intra-EU operations for a long period, ask your gestor whether you should deregister.

Step 3: write the invoice to an EU client with reverse charge wording

An invoice to an EU business client contains the usual mandatory fields plus the information that explains why no VAT is charged.

Element	What to include
Your details	Name, address and Spanish NIF (your EU VAT number: ES + NIF)
Client details	Legal name, address and EU VAT number
Invoice number and date	Consecutive numbering and issue date
Description	The service and the period it covers
Amount	The net amount, with the currency; VAT is 0 or not shown
VAT mention	A note such as «Reverse charge – VAT to be accounted for by the recipient» and the legal reference
Payment details	IBAN, due date and payment terms

A typical wording that freelancers use is: «Operation not subject to Spanish VAT by place-of-supply rules (Article 69.One.1 of the Spanish VAT Law). Reverse charge – VAT to be accounted for by the recipient (Article 196 of Directive 2006/112/EC).» Ask your gestor to confirm the exact legal references that apply to your service. You can reuse the text in the freelance invoice template in English.

Step 4: report the operation after you invoice an EU client

Invoicing correctly is not enough. You must also report the operation in your returns.

Modelo 303 (quarterly VAT): the operation is reported in the box for services supplied under the reverse charge, with the taxable amount.
Modelo 349 (intra-EU summary): you list each EU client by VAT number, the amount and the key that identifies a service provision. Its frequency depends on the amount of your intra-EU operations. As a general guide it is quarterly if your volume stays below the threshold and monthly if it exceeds it, with an annual option for very small volumes. Check the current thresholds and deadlines with the Agencia Tributaria.
Modelo 130 (income tax prepayment): the income is included in the usual way.

Invoice an EU client: example with a German company

You are a freelance designer in Spain and you invoice a German company for €2,400 of design work.

Item	Value
Client	Example GmbH, Berlin, VAT number DE123456789 (validated in VIES)
Net amount	€2,400.00
Spanish VAT	€0.00 (reverse charge)
IRPF withholding	None: the client is not established in Spain
Total to pay	€2,400.00 by SEPA transfer

The client pays €2,400 and accounts for German VAT in its own return. You report the operation in your modelo 303 and modelo 349. Because the payment is in euros inside the SEPA area, the transfer should arrive without conversion costs. Read SEPA vs SWIFT for details.

What if the client is a private person?

When the EU client is a consumer, the reverse charge does not apply. In most cases you charge Spanish VAT at the applicable rate. There are exceptions for some digital services, telecommunications and broadcasting supplied to consumers in other EU countries, which can be taxed in the consumer’s country under the One Stop Shop (OSS) scheme, with a EU-wide annual threshold below which you can keep applying the VAT of your own country. If you sell this kind of service to consumers, check the OSS rules with a gestor before you invoice.

Common mistakes when you invoice an EU client

Charging Spanish VAT to a business with a valid EU VAT number.
Not validating the number in VIES, or not saving the evidence.
Invoicing without VAT before being registered in the ROI.
Forgetting modelo 349 or filing it late.
Leaving out the reverse charge wording and the legal reference.
Using the client’s trading name instead of its legal name.
Applying IRPF withholding to a client in another EU country.
Assuming that every service follows the general rule, without checking the exceptions.

If you issue an invoice with an error, correct it with a credit note. See how to issue a corrective invoice for a foreign client.

Frequently asked questions about invoice an EU client

Do I charge VAT when I invoice an EU client?

Not if the client is a business established in another EU country with a valid EU VAT number and the service follows the general rule. In that case the reverse charge applies and the client accounts for the VAT.

How do I check an EU client’s VAT number?

Use the VIES VAT validation service of the European Commission. Enter the country code and the number, and keep the confirmation as evidence.

Do I need to be in the ROI to invoice an EU client?

If you supply services to EU businesses without VAT, you normally need to be registered in the ROI through the census declaration (modelo 036). Confirm with a gestor.

What is modelo 349?

It is a summary return in which you report your intra-EU operations, such as services supplied to businesses in other EU countries. Its frequency depends on your volume.

What wording should I use on the invoice?

A common wording states that the operation is not subject to Spanish VAT by the place-of-supply rules and that the reverse charge applies, with the legal references. Ask a gestor to confirm the references for your service.

What if the client is a consumer in another EU country?

The reverse charge does not apply. Spanish VAT usually applies, except for some digital services that follow the One Stop Shop rules.

Final thoughts on invoice an EU client

To invoice an EU client without errors, validate the VAT number, register in the ROI, use the reverse charge wording and report the operation on modelo 349. Once you have a template and a checklist, you can invoice an EU client in a few minutes and keep your tax returns clean. Review the rules once a year, because thresholds and forms change.

Sources and further reading

Related guides

Disclaimer: This article is for general information only and is not tax, legal or financial advice. Rules, fees and thresholds change often and differ by country; always confirm current details with the tax authority and a qualified adviser. Some links may be affiliate links, which means we may earn a commission at no extra cost to you.

How to Invoice an EU Client from Spain: VAT, ROI and Reverse Charge