Billing abroad from Spain

When setting up a business, you might not initially plan to sell your products or provide your services abroad. However, this situation may arise. Let’s look at how to invoice foreign customers from Spain.

Is it Possible to Invoice Foreign Customers from Spain?

The answer is clearly yes.

Both freelancers (autónomos) and companies can invoice individuals or legal entities outside of Spain. However, you must take into account certain tax considerations when doing so, primarily regarding the application of Value Added Tax (VAT).

What Procedures are Necessary for Invoicing Foreign Customers?

Intra-Community Operators Register (ROI): If you are going to carry out supplies of goods or provision of servicesto othercompanies or professionals in the European Union (EU), it is mandatoryto register in the ROI to invoice them without VAT (applying the reverse charge rule).
- To complete this procedure, you must submit Form 036 (Modelo 036) to the Tax Agency (Agencia Tributaria). Once accepted, you obtain a NIF-VAT (or intra-community VAT number) that must appear on your invoices. You can check if your EU client is registered in the European Commission’s VIES system.
Invoices to non-EU customers (outside the EU) or private customers in the EU: Generally do not require registration in the ROI, but may require other special registrations in the case of EU private customers (see point 2).
Invoice Mention: It is necessary to indicate the applicable regulation on the invoices you issue (e.g., “Operation exempt under Art. 21 of Law 37/1992” for exports).

Furthermore, when invoicing foreign customers, it is essential to differentiate the type of customer and the location:

1. Professional Customers or Businesses in the European Union

Intra-community customers are considered those who reside or have their registered office in an EU member country.

General Rule: When the issuer (Spanish supplier) and the recipient (EU client) of the invoice are registered in the ROI/VIES, the invoice is issued without VAT. This is the reverse charge rule, where the VAT is self-assessed in the country of destination.
Declaration: These operations must be included in the VAT Form 303 (Modelo 303) and in the Form 349 (Modelo 349) for intra-community operations (where the sales made are declared).

2. Private Customers (Final Consumers) in the European Union

In this situation, the VAT applied depends on the type of operation and the total annual sales amount:

Customer Type	Applicable VAT Regulation
Goods and Digital/Telecommunications Services	The VAT of the country of destination (where the individual resides) applies from the first euro.
Distance Sales of Goods and General Services	€10,000 Net Threshold: The total value of distance sales of goods and digital/telecommunications services to all private customers in the EU must be calculated.
· If the €10,000 threshold is NOT exceeded	Spanish VAT applies, and the operation is declared as a normal domestic sale (Form 303).
· If the €10,000 threshold IS exceeded	It is mandatory to apply the VAT of the country of destination (the buyer’s country).

One Stop Shop Scheme (OSS): If you exceed the €10,000 threshold and must apply the destination country’s VAT. To avoid registering in every country, you can register for the One Stop Shop (OSS) Scheme in Spain.
- The OSS allows you to declare and pay the VAT for all EU countries in a single quarterly declaration in Spain (Form 369 – Modelo 369), greatly simplifying management.
Note: These invoices are not included in Form 349, as this is only for operations with professionals/businesses.

3. Customers Outside the European Union (Exports)

When the invoice is issued to a customer (individual or company) outside the European Union:

VAT: The operation is exempt from VAT (Art. 21 of the VAT Law applies). The invoice is issued without VAT.
IRPF: IRPF (Personal Income Tax retention) is not included (retention only applies between professionals residing in Spain).
ROI: It is not necessary to be registered in the ROI.
Invoice: Issuing an invoice to a non-EU customer is very simple. You only need to include the price of the products or services to be charged and the reference to the VAT exemption.

In Summary

Based on what we have seen, the key factors to consider when invoicing customers who are not in Spain are:

Whether you are offering a product or a service (and its nature, e.g., digital or general).
Whether your customer is in an EU country or outside of it.
Whether your customer is a company/freelancer or a private individual.

This will influence whether you have to add any tax like VAT, the obligation to register for the ROI, and, in the case of private EU customers, whether you must opt into the One Stop Shop (OSS) Scheme. In case of doubt, we always recommend consulting aspecialized advisor on the subject, like our german lawyer Jens Gerl.

Further information

This article is part of our service Business consulting. Visit this section where you will find all the useful information on this topic, including a complete guide on How to start a business in Spain as a foreigner.

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