You live in Spain, you are registered as an autónomo or run a small company, and your best clients are in Germany, London or New York. Sooner or later the same question comes up when you prepare an invoice: do I add 21% IVA or not? Get it wrong in one direction and you overcharge your client and lose competitiveness; get it wrong in the other and the Agencia Tributaria can claim the tax from you, plus surcharges.

The good news is that the logic is consistent once you understand one idea: Spanish IVA is charged where the service or sale is legally located, and for most cross-border work by freelancers that place is the client's country, not Spain. This guide walks through the four situations you will meet in practice (EU business, EU consumer, non-EU business and non-EU consumer) and shows exactly what to write on the invoice. If you need a refresher on rates and the basics of the tax first, start with our complete guide to IVA in Spain.

The key idea: place of supply decides whether IVA applies

IVA is regulated by the Ley 37/1992 del Impuesto sobre el Valor Añadido. Its articles on the lugar de realización (place of supply) decide which country has the right to tax each operation. Spanish IVA only applies if the operation is located in the Spanish IVA territory, which excludes the Canary Islands, Ceuta and Melilla.

For services, two general rules do most of the work:

  • B2B (your client is a business or professional): the service is located where the client is established. A consultancy service for a company in Paris is located in France, so it is outside Spanish IVA.
  • B2C (your client is a private individual): the service is, in general, located where you, the provider, are established. A service to a private person is therefore usually subject to Spanish IVA, with important exceptions explained below.

Goods follow different rules (exempt intra-community supplies and exports), which we cover in a separate section. Everything else in this article builds on these two rules, so it is worth identifying your client type before anything else.

Invoicing a business in another EU country

This is the most common case for Spanish freelancers: a designer billing an agency in Amsterdam, a developer working for a start-up in Berlin, a translator for a firm in Milan.

No Spanish IVA, the client self-assesses

Because the service is located in the client's country, you issue the invoice without Spanish IVA. The client accounts for the VAT in their own country through the reverse charge mechanism (inversión del sujeto pasivo). Your invoice must say so explicitly, for example: "Operación con inversión del sujeto pasivo – Reverse charge", with a reference to the place-of-supply rule (article 69 of Ley 37/1992).

Check the VAT number in VIES

The B2B treatment depends on proving that your client really is a business. The standard proof is a valid EU VAT number, which you can verify in the European Commission's VIES database. Keep a screenshot or record of the check with the invoice. If the client cannot give you a valid VAT number, treat the operation with caution and check with your adviser before removing IVA.

Register as an intra-community operator

To invoice EU businesses without IVA you also need your own Spanish tax number to appear in VIES, which means being registered in the Registro de Operadores Intracomunitarios (ROI). You request it through your census declaration with the Agencia Tributaria (Modelo 036). Many new autónomos only discover this when a client tells them their NIF "does not validate" in VIES.

Report it in Modelo 349 and Modelo 303

Services billed to EU businesses must be declared in the informative Modelo 349, under the key for intra-community services provided. If you have never filed it, our guide to Modelo 349 and intra-community operations explains who must file and how often (in Spanish). The same invoices also appear in your quarterly Modelo 303, in the informative boxes for operations not subject to Spanish IVA under the place-of-supply rules.

Invoicing clients in the UK, the US and other non-EU countries

Since Brexit, the United Kingdom is treated like any other country outside the EU for services. The rule for business clients is the same as within the EU: the service is located where the client is established, so it is not subject to Spanish IVA.

The differences from the EU case are practical:

  • There is no reverse charge in the EU sense and no VIES check. Instead, keep evidence that the client is a business: company name, address, company or tax registration number and the contract or order.
  • These invoices are not included in Modelo 349, which only covers EU counterparties.
  • The invoice should state the reason why no IVA is charged, for example: "Operación no sujeta a IVA en España por reglas de localización (art. 69 Ley 37/1992)".

Whatever your client does with VAT, GST or sales tax in their own country is their obligation, not yours. A US client, for example, will not expect any VAT on your invoice at all.

Invoicing private individuals abroad (B2C)

Private clients are where most mistakes happen, because the general B2C rule points back to Spain.

EU consumers

If you provide a standard service (coaching, design, consulting) to a private individual in another EU country, the general rule places it in Spain, so you charge Spanish IVA as you would to a client in Madrid.

The big exception is electronically supplied services, telecommunications and broadcasting: online courses delivered automatically, downloadable templates, software subscriptions, digital content. These are taxed in the consumer's country. Below an EU-wide threshold of €10,000 per year in cross-border sales of this kind you can keep applying Spanish IVA; above it, you charge the VAT of each customer's country and declare it through the EU One-Stop Shop (ventanilla única, OSS) instead of registering in every country.

Non-EU consumers

For private individuals outside the EU, a specific list of services is located where the customer lives and is therefore outside Spanish IVA. The list includes, among others, consulting and advisory services, legal and accounting work, advertising, translation, data processing and the supply of information, and electronically supplied services. Services that are not on that list may still carry Spanish IVA. Because the boundaries are technical, check the specific case against article 69 of the IVA law or with your adviser before removing the tax.

Exceptions where Spanish IVA still applies to foreign clients

Some services are taxed where they physically happen, regardless of who the client is. If any of these take place in Spain, you will usually charge Spanish IVA even to a foreign business:

  • Services related to real estate located in Spain (architecture, property management, renovation work).
  • Admission to events, conferences or trade fairs held in Spain.
  • Restaurant and catering services, and passenger transport within Spain.
  • Short-term hire of means of transport made available in Spain.

The reverse is also true: if you organise a workshop in Lisbon for a Portuguese client, the place of supply is Portugal and you may have obligations there. When in doubt, read the specific rule for your type of service before invoicing.

What about selling goods to foreign customers?

If you ship physical products, the logic changes:

  • EU business customers: the sale is an exempt intra-community supply (article 25 of Ley 37/1992) when the customer has a valid VAT number and the goods actually leave Spain. Keep transport documents as proof, and report the sale in Modelo 349.
  • EU consumers: distance sales are taxed in the customer's country once you exceed the same €10,000 EU-wide threshold, and can be declared through the OSS.
  • Outside the EU, including Great Britain: the sale is an exempt export (article 21), supported by the customs export documentation. Northern Ireland is a special case: for goods it still follows EU VAT rules.

What to put on an invoice to a foreign client

An invoice without IVA is still a full Spanish invoice and must meet every legal requirement. On top of the usual details explained in our guide to invoice legal requirements in Spain, make sure it includes:

  1. Your NIF and, for EU business clients, the client's VAT number with its country prefix.
  2. The client's full legal name and foreign address.
  3. A clear description of the service and the date it was performed.
  4. The taxable base and an IVA line at 0 or "exempt / not subject", never simply left blank.
  5. The legal mention that explains why there is no IVA: reverse charge, not subject under place-of-supply rules, or exempt export.
  6. The currency. You can invoice in dollars or pounds, but the IVA amount, if any, must be expressed in euros. Our guide to invoicing international clients in multiple currencies covers exchange rates and payment options.

You may write the invoice in English or bilingually. The Agencia Tributaria can ask for a translation, so a Spanish-English layout is a sensible default.

IRPF withholding does not apply to foreign clients

A frequent question from freelancers who usually bill Spanish companies: do I still deduct the 15% (or 7%) IRPF withholding? No. The retención is an obligation of Spanish payers. A company in the UK or the US has no obligation to withhold Spanish income tax, so your invoice to them shows no IRPF line. You then pay the tax on that income yourself through your quarterly Modelo 130 payments and your annual return. Read more in our guide to IRPF withholding on freelance invoices.

Common mistakes Spanish freelancers make with foreign clients

  • Removing IVA for an EU client without being in the ROI. Your NIF must validate in VIES as well as your client's.
  • Treating every foreign client as a business. A private individual in France usually pays Spanish IVA on a standard service.
  • Forgetting the legal mention. An invoice without IVA and without the reason looks like an error to an inspector.
  • Skipping Modelo 349. EU business services must be reported even though no IVA was charged.
  • Assuming VeriFactu does not apply. The new rules on billing software apply to every invoice you issue, including those to foreign clients. See our overview of the VeriFactu electronic invoicing law for the 2027 timeline.

Quick reference: does my invoice carry Spanish IVA?

  • EU business, standard service: no IVA, reverse charge, report in Modelo 349.
  • EU consumer, standard service: Spanish IVA.
  • EU consumer, digital/electronic service: Spanish IVA up to €10,000 per year EU-wide; above that, customer's country VAT via OSS.
  • Non-EU business (UK, US): no IVA, not subject under place-of-supply rules.
  • Non-EU consumer: depends on the type of service; many professional services are not subject.
  • Service tied to Spanish real estate or an event in Spain: Spanish IVA, whoever the client is.

Rules and thresholds can change, so for edge cases always verify with the Agencia Tributaria's official information on IVA or with your gestoría.

Invoice foreign clients correctly with Facturi

Facturi lets you save each client with their country and VAT number, choose the right tax treatment once, and automatically add the reverse-charge or not-subject mention to every invoice. You can bill in euros, pounds or dollars, issue bilingual invoices and export the data you need for Modelo 303 and Modelo 349, all from a system built for the VeriFactu requirements. Try Facturi free and stop guessing whether to add IVA.

Frequently asked questions

Do I charge IVA to a client in the UK after Brexit?

Not if the client is a business and you provide a standard service: it is located in the UK and is not subject to Spanish IVA. State the reason on the invoice. For private individuals, it depends on the type of service.

Do I need to be in the ROI to invoice US clients?

No. The Registro de Operadores Intracomunitarios is only required for operations with businesses in other EU countries.

My EU client's VAT number is not valid in VIES. What do I do?

Ask the client to confirm their number and registration for intra-community operations. Until it validates, you cannot rely on the reverse charge, and the safe option is to consult your adviser before issuing the invoice without IVA.

Can I invoice a foreign client in dollars?

Yes. Invoices can be issued in any currency, but any IVA charged must also be shown in euros, and your accounting records must be kept in euros.