Invoicing EU clients from Spain: services, goods and VAT

Classify the sale before deciding the VAT

This guide is for autónomos, self-employed people established in mainland Spain or the Balearic Islands under Spain’s common tax administration. B2B means a customer buying for their business; B2C means a consumer buying privately.

An EU address does not make every invoice VAT-free. First identify goods or services, a business acting as such or a consumer, and the destination relevant to that particular supply. For services, identify the establishment receiving and using them. For goods, establish where transport begins and ends. A VAT number alone cannot answer these questions.^[7]

General B2B services supplied to an EU business

A general service supplied from Spain to a business acting as such and receiving it at its establishment in another Member State is normally outside the scope of Spanish VAT. Check special rules first, including those for property, admission to events, restaurants or transport. This treatment is different from an export exemption; use reverse-charge wording when the recipient is liable for the tax.

Request the customer’s VAT number, check it in VIES, the EU VAT-number validation tool, and save the dated result. Also confirm which establishment receives and uses the service: review the contract, order, payment details and the work itself. A valid VAT number or registered address does not settle this on its own.

If VIES returns an invalid result, check why. For services, a customer who says they have applied for a number but not yet received it may be able to establish business status through other evidence and reasonable commercial checks, absent contrary information. This is not a general workaround for invalid numbers and does not replace the conditions for exempt goods supplies.^[8][7]

Complete invoice example for an EU business

The wording accompanies the VAT treatment of this service. Before using the example, replace every fictional detail and check VAT and income-tax withholding for your transaction.^[1][4][12]

Goods sent to another EU Member State

For an exempt intra-Community supply, the goods must actually travel to another Member State and the customer must meet the qualifying conditions. They must give you a VAT number assigned by a Member State other than Spain, and you must include the sale in modelo 349 and meet the remaining exemption conditions. Keep the transport evidence and the number: an EU billing address does not prove the goods moved.

Do not copy the alternative evidence rule for a pending service customer VAT number into this goods test. Nor should you apply this short route to chain transactions, installed goods, new means of transport, used-goods margin schemes or other special cases without checking their rules.^[7]

ROI, VIES and modelo 349 are not the same thing

The 349 is an information return, not the mechanism for paying VAT. Do not file it for periods without reportable transactions. Determine its reporting period from your actual operations rather than assuming every self-employed person files quarterly. Applying for ROI, receiving approval and checking VIES are separate steps.^[2][3][11]

Services supplied to EU consumers

For an ordinary B2C service, the general rule places the supply where the supplier is established: normally Spanish VAT for a supplier in mainland Spain or the Balearic Islands. There are exceptions. Telecommunications, broadcasting and electronically supplied services have specific destination rules. A service is not automatically an electronically supplied service just because you communicate or send the work by email.^[7]

The €10,000 threshold is conditional and aggregate

The €10,000 threshold combines qualifying intra-Community distance sales of goods and cross-border B2C telecommunications, broadcasting and electronically supplied services. It is not a threshold for all services, all turnover or each country.

1. 1

   Check your establishment and dispatch location

   To use the origin-taxation exception, you must be established in only one Member State and the relevant goods must be dispatched from that State.

2. 2

   Check both years and any election

   The combined amount excluding VAT must not have exceeded €10,000 in the previous year or the current year. Check that you have not elected destination taxation.

3. 3

   Identify the sale that crosses the threshold

   Fictional example: established only in Spain, you dispatch the goods from Spain, stayed within the threshold last year and have not elected destination taxation. This year, €8,000 in qualifying distance sales plus €3,000 in qualifying digital services make €11,000. The whole transaction that crosses the threshold is taxed at destination; exactly €10,000 does not exceed it.

At Finlai, we recommend keeping the VIES check with the contract and invoice so you can find the client’s evidence when preparing your quarterly returns.

The One Stop Shop (OSS) can simplify reporting destination VAT for eligible transactions; it does not remove the tax. Check eligibility and registration separately. Stock in another country, a marketplace or multiple establishments can change the analysis.^[7][9]

If the customer is outside the EU VAT territory

Stop applying the intra-Community checklist automatically. General B2B services, services to consumers and exports of goods follow different routes. Supplying a third-country customer does not itself require VIES or a 349, but other transactions may still create registration and reporting obligations. The Canary Islands, Ceuta and Melilla are part of Spain but outside its VAT territory; they are not foreign countries and have their own indirect taxes.^[7]

What the invoice should contain

• A sequential number and series, the issue date and the transaction date when different.
• Your legal name, tax number and address, and the equivalent customer details.
• A clear description of the goods or services, taxable amount and currency. Show the VAT rate and amount when you charge VAT.
• The customer’s VAT number when required, particularly when the intra-EU treatment depends on their business status.
• The relevant wording if the transaction is exempt or subject to reverse charge. Do not call a transaction “exempt” when it is actually outside the scope of Spanish VAT.

VAT and Spanish income-tax withholding are separate questions

Review Spanish income-tax withholding (IRPF) separately from VAT. It depends on your activity, the payer and the income-tax rules, rather than the customer’s country alone. Ask your adviser to review the case if the payer’s tax residence, a treaty or another country’s obligations are relevant.^[5]

Match the invoice to the correct 303 and 349 entries

For 2026, box 59 of modelo 303, Spain’s VAT return, covers exempt intra-Community goods supplies and reportable intra-Community services supplied. It is not for purchases or every foreign invoice. Non-taxable supplies reported through OSS follow a different route, including box 123 where applicable: check the instructions for your period and reconcile the invoices, 303 and 349.^[10]

Examples: the same amount can have a different VAT basis

• Different fictional case: goods worth €2,000 are actually sent from Madrid to France. If all Article 25 conditions are met, the supply is exempt and the total is €2,000 without other items. The same total does not turn the goods exemption into the service place-of-supply rule.
• An ordinary design service supplied from Spain to a French consumer generally carries Spanish VAT unless a special rule applies. Delivering the design by email does not by itself decide the classification.
• A self-employed person in Spain buys an Irish SaaS subscription. This is a received service, not a sale: check the recipient’s VAT obligations, reverse charge and the relevant 303 and 349 entries. Do not put purchases in the 303 box for services supplied.

Checklist before you issue the invoice

1. Confirm whether you are selling goods or services.
2. Classify the customer as a business/professional or a consumer and document where they are established.
3. Check whether a special place-of-supply rule applies to the service.
4. For intra-EU B2B services, review ROI, validate VIES and save the result.
5. Determine the VAT treatment and review income-tax withholding separately.
6. Include the correct wording on the invoice and record the transaction.
7. Flag it for modelo 349 when applicable and retain it for the Spanish tax close.

Confirm the scope before handing over the work

Prepare the contract, customer details, VAT evidence, invoices and any transport documents. If you are considering Finlai, ask which Spanish obligations are included for your specific activity and who will handle each return and period.

Finlai is an online accountancy for self-employed people without employees in Spain who want a human advisor to handle their taxes. Gold includes bookkeeping, quarterly returns, the annual income tax return and a dedicated advisor. It costs €49.90 per month plus VAT, or €42.90 per month plus VAT when billed annually at €514.80 plus VAT. You upload your invoices and your advisor reviews them. If you only need to issue invoices, compare standalone invoicing software first.

This guide does not cover foreign registrations, regional tax administrations or every special VAT scheme. Confirm who handles ROI registration, OSS, customs, IGIC, IPSI, foreign returns or multiple establishments before handing over the work. Use proper authorisation rather than sharing passwords or private certificate keys.

Start with the Finlai online accounting service description to check the service.