Invoicing Foreign Clients as an Autónomo in Spain

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The rule: business client or private client
Business client in the EU
Client outside the EU
What the invoice must say
IRPF withholding does not apply to foreign clients
Digital nomad visa holders: the 20% limit
What VeriFactu changes
Sources
Who can do this for you

The rule: business client or private client

Spanish IVA (VAT) law decides where a service is taxed. For most services, AEAT summarises it like this: a service to a business is taxed where the business is based, and a service to a private person is taxed where the provider is based. If you work from Spain, that gives three cases.

Client is a business in another EU country: no Spanish IVA. The service is taxed in the client's country.
Client is a business outside the EU: no Spanish IVA.
Client is a private person, in the EU or not: Spanish IVA applies, with exceptions for some services to private clients outside the EU (see below).

The law behind this is article 69 of the IVA law (Ley 37/1992). Point 1 covers business clients and point 2 covers clients who are not "un empresario o profesional que actúe como tal". Article 70 has special rules for some services, such as those tied to property in Spain, events held in Spain, and electronic services sold to private clients. This guide does not cover those.

Business client in the EU

AEAT says that when a Spanish-based business serves a business in another country, the operation is no sujeta (not subject) to Spanish IVA, and you keep the right to deduct the IVA on your own costs for that work. For an EU client it adds that this is an intra-EU service and goes on Modelo 349. Three practical steps follow.

Register in the ROI. AEAT requires entry in the Registro de Operadores Intracomunitarios for businesses that provide services located in another Member State where the client is the taxpayer. You ask for it on Modelo 036 (box 582, with the date of your first operation in box 584). That gives you the EU VAT number (NIF-IVA).
Check the client's VAT number. AEAT points to VIES, the EU database, to check a customer's VAT number.
Report it on Modelo 349. This is the summary return of intra-EU operations. Services you provide go under key S. Check the filing period in AEAT's instructions, which this guide does not reproduce.

If the EU client has no VAT number. The law asks whether the client is a business acting as a business, not whether they hold a number. A client with no number may still be a business, or may be a private person, and the second case brings Spanish IVA. We found no AEAT page that settles this by itself. Ask your gestor before you invoice without IVA.

Client outside the EU

For a business client in the US, the UK or elsewhere outside the EU, the same article 69 point 1 applies, so there is no Spanish IVA. The ROI and Modelo 349 are for intra-EU operations, so they do not apply to these clients.

For a private person outside the EU, the default is Spanish IVA. Article 69 point Dos lists services where that default does not apply when the client is outside the EU and not a business. The list includes advertising, advice, audit, engineering, legal and accounting services, data processing, and translation. If you sell something else to private clients abroad, check article 69 or ask a gestor.

What the invoice must say

You must issue an invoice even when there is no IVA. The invoicing rules (Real Decreto 1619/2012) cover operations that are not subject and those that are exempt. Article 6 lists what every invoice contains. The main items are:

A number, in a correlative sequence, and a series if you use one.
The issue date, and the date of the service if it differs.
Full name or company name, and address, for you and for the client.
Your NIF, and the client's tax number where the rules require it.
A description of the service, its price without tax, and any discount.
The IVA rate and amount, if any, shown separately.

Two points matter for foreign business clients. First, the client's tax number is mandatory when the client is the one liable for the tax on the operation. Second, when the client is the taxpayer, the invoice must carry the words "inversión del sujeto pasivo" (reverse charge).

On exemption wording: the rule that asks for a reference to the law or the word "exenta" applies to exempt operations. A service to a foreign business under article 69 is not subject to the tax, which is a different thing. The regulation does not prescribe a set phrase for it. A common choice is to cite article 69 of the IVA law, but we could not confirm a prescribed wording, so ask your gestor which one they use.

Language and currency are free. Invoices may be written in any language. The tax authority can ask for a Spanish translation for operations in Spain. Amounts may be in any currency, but any IVA you charge must be shown in euros.

IRPF withholding does not apply to foreign clients

The 15% withholding on professional invoices (7% in the first three years for new professionals who have not worked as one in the year before starting) is set by article 95 of the IRPF regulation. Who must withhold is set by article 76. It lists Spanish companies, self-employed people paying for their activity, and non-residents who operate in Spain through a permanent establishment. A foreign client with no Spanish presence is not on that list, so it does not withhold, and your invoice to them has no retención line. This is our reading of article 76, not a sentence AEAT states in so many words. Your own quarterly filings still apply: see tax deadlines for autónomos.

Digital nomad visa holders: the 20% limit

If you hold the teleworking residence, article 74 bis of Law 14/2013 says that for professional activity you may work for a company located in Spain "siempre y cuando el porcentaje de dicho trabajo no sea superior al 20 % del total de su actividad profesional". The text does not say how the 20% is measured, for example by income, by invoices or by hours. Your foreign-client invoices are what keep you under it, so keep them. See becoming an autónomo after the digital nomad visa.

What VeriFactu changes

VeriFactu comes from Real Decreto 1007/2023. It applies to self-employed people who pay IRPF on business activity (article 3.1.b) and who use invoicing software. The rules cover the software that issues your invoices. They keep the content rules above unchanged. The regulation excludes only invoices for operations through permanent establishments abroad. A Spanish autónomo billing a foreign client is not in that exception.

Dates. The BOE text in force, as changed by Real Decreto-ley 15/2025, says autónomos must have systems in operation "antes del 1 de julio de 2027", and companies paying Corporate Income Tax before 1 January 2027.

This may move. On 5 October 2026 the Ministry of Hacienda announced that it expects to postpone the pending obligations to October 2028, to line up with e-invoicing for businesses under 8 million euros of turnover. When we checked, AEAT's own notice still showed the 1 July 2027 date, and we did not find an approved norm for the new date. Check the BOE before you rely on either.

A free option exists. AEAT offers a free invoicing application. Its guide says it generates invoices with a QR code and sends the billing record to AEAT. It is aimed at self-employed people who issue few invoices or have simple billing. It does not issue simplified invoices, so every invoice needs a client. We did not verify how it handles foreign clients or invoices without IVA, so test it before you depend on it.

Sources

Who can do this for you

The ROI registration, the Modelo 349 and the business or private client question are quick for a gestor and easy to get wrong alone. An accountant can also pick invoicing software that will meet the VeriFactu rules.

Gestors: Modelo 036, the ROI and the paperwork side
Accountants: IVA treatment of each client and your invoicing setup

This page is general information, not legal advice. It was checked against the sources above on the date shown. The VeriFactu dates in particular may change, so confirm them with a gestor or in the BOE.