A client in London, Paris or Brussels can hire you without leaving their desk. The questions start with the invoice: Spanish VAT (IVA) or not? What must it say? Any extra return? This guide sums up the rules in force in September 2026 for an autónomo established in mainland Spain or the Balearic Islands who supplies services, not goods, to clients in the EU or the UK.
Two questions decide everything
Is your client a business (or a professional acting as such) or a private individual? Are they in the EU or outside it, like the UK? From those answers, Article 69 of Spain's VAT Act (Ley 37/1992) sets the place of supply. Article 70 adds special rules (property, transport, restaurant services or events, among others): if one applies, it depends, so check the Agencia Tributaria's service locator (Localizador de prestación de servicios). And even without Spanish VAT, an invoice is compulsory (Real Decreto 1619/2012, Article 2).
Business clients in another EU country
Under Article 69 of Ley 37/1992, a service supplied to a business is taxed where that business is established. For a client in Ireland, France or any other member state, there is no Spanish VAT: the client accounts for the VAT in their own country through the reverse charge, as the Spanish Tax Agency (Agencia Tributaria) explains. It mirrors Article 84 of the Act, applied in Spain when the supplier is not established here.
Article 6 of Real Decreto 1619/2012 requires the wording ‘Inversión del sujeto pasivo’ and the client's VAT number, and allows extra wording such as ‘Reverse charge’. Under Article 11 of Real Decreto 1619/2012, a business client must be invoiced before the 16th of the month after the VAT became chargeable.
Before the first invoice, you must be on the Register of Intra-Community Operators (Registro de Operadores Intracomunitarios, ROI). According to the Agencia Tributaria, you apply on Modelo 036 (box 582, with the expected date of your first transaction in box 584); with no decision within three months, the application may be treated as refused. Check your client's number in VIES, on the Agencia Tributaria website or the European Commission's VIES portal, and keep the reply, which proves the check if you use your own EU VAT number. No valid number? Do not apply the reverse charge by default: it depends.
These invoices go in box 59 of your Modelo 303 VAT return (Agencia Tributaria's 2026 instructions) and in Modelo 349 under key ‘S’, only for periods with such supplies. Under Article 81 of the VAT Regulation (Real Decreto 1624/1992), Modelo 349 is quarterly as long as neither the quarter nor any of the previous four exceeds €50,000 of these supplies, due within the first 20 days of the following month (last quarter: by 30 January); otherwise it is monthly.
Private clients in another EU country
Here the rule flips: Article 69 of Ley 37/1992 places a service to a private individual in Spain, where you are established. You charge Spanish VAT as for a local client; the standard rate is 21% under Article 90 of Ley 37/1992, unless a reduced rate or exemption applies.
The key exception is electronically supplied services (Article 69.Tres): according to the Agencia Tributaria, essentially automated services with minimal human intervention, such as website hosting, downloads or automated distance learning. Advice by email and lessons given by a teacher over the internet are not.
For these services, Article 73 of Ley 37/1992 sets a €10,000 annual limit, excluding VAT, on the total supplied to consumers in other EU countries (together with telecoms, broadcasting and distance sales of goods). If you are established only in Spain and stayed below it last year and so far this year, you charge Spanish VAT (you may opt for destination taxation, for at least two years under that Article 73). Above it, the client's country's VAT applies. The One-Stop Shop (ventanilla única, Union scheme) is optional and spares you registering in each country: Form 035, a quarterly Modelo 369 and box 123 of Modelo 303, says the Agencia Tributaria.
UK clients after Brexit
The UK is outside the EU: no ROI, VIES or Modelo 349 for UK clients. For a UK business, the service is taxed where it is established (Article 69 of Ley 37/1992), so there is no Spanish VAT. The invoicing regulation sets no compulsory wording here, but it is sensible to state ‘Operación no sujeta al IVA español (artículo 69 de la Ley 37/1992)’. It goes in box 120 of Modelo 303. On the UK side, HMRC's VAT Notice 741A says the UK business accounts for the VAT under the reverse charge; check its number with HMRC's ‘Check a UK VAT number’ service. You may invoice in English and in pounds (Article 12 of Real Decreto 1619/2012), but any Spanish VAT charged must be shown in euros.
For a UK private client, Spanish VAT is the general rule (Article 69.Uno.2.º). However, Article 69.Dos takes certain services out of Spanish VAT when the individual is established or lives outside the EU (other than in the Canary Islands, Ceuta or Melilla), including: transfers of copyright, patents, licences, trade marks and other intellectual or industrial property rights; advertising; advisory, audit, engineering, research, legal, consultancy, accounting or tax services and similar (except those connected with property in Spain); data processing and the supply of information; and translation, proofreading or composition of texts and interpreting (full list: letters a) to l)). They carry no Spanish VAT unless the client actually uses them in Spain (Article 70.Dos).
Electronically supplied services to UK consumers are outside the scope of Spanish VAT according to the Agencia Tributaria (unless effectively used in Spain), but HMRC says they are liable to UK VAT and a supplier based outside the UK must register there, unless it sells through a platform that accounts for the VAT.
What about IRPF withholding?
Usually none. Article 99 of the IRPF Act (Ley 35/2006) and Article 76 of its Regulation (Real Decreto 439/2007) only make non-residents withhold if they operate in Spain through a permanent establishment or in specific cases. A foreign client with no establishment in Spain does not withhold: no IRPF line on your invoice. If they have a branch or office in Spain, it depends. Note that under Article 109 of the IRPF Regulation, a professional is only exempt from Modelo 130 payments on account if at least 70% of the previous year's income was subject to withholding.
Summary
| Client | Spanish VAT? | Invoice wording | Returns |
|---|---|---|---|
| EU business with a valid VAT number | No (Art. 69 Ley 37/1992) | ‘Inversión del sujeto pasivo’ and client's VAT number | ROI first (036); 303, box 59; 349, key S |
| EU consumer (general rule) | Yes (Art. 69 Ley 37/1992) | Spanish VAT | 303 |
| EU consumer, electronically supplied services | Yes up to €10,000 (Art. 73 Ley 37/1992); above it, their country's VAT | Applicable VAT | 303; One-Stop Shop (035 and 369) above the limit |
| UK business | No (Art. 69 Ley 37/1992) | Recommended: ‘Operación no sujeta al IVA español (art. 69 Ley 37/1992)’ | 303, box 120 |
| UK consumer, Article 69.Dos services | No, unless used in Spain (Art. 70.Dos Ley 37/1992) | Recommended: ‘Operación no sujeta (art. 69.Dos Ley 37/1992)’ | 303, box 120 |
| UK consumer, electronically supplied services | Not in Spain (Agencia Tributaria) | It depends: UK VAT (HMRC) | 303, box 120; UK VAT registration |
| UK consumer, other services | Yes (Art. 69 Ley 37/1992) | Spanish VAT | 303 |
Official sources checked on 28 September 2026: Ley 37/1992 (VAT Act), Real Decreto 1619/2012, Real Decreto 1624/1992, Ley 35/2006 and Real Decreto 439/2007 (IRPF), Agencia Tributaria pages (ROI, VIES, Modelos 303 and 349, electronic services, One-Stop Shop) and HMRC guidance (VAT Notice 741A and digital services to consumers).
This guide is general information on the rules in force in September 2026, not tax advice: check your own case with a gestor or tax adviser (asesor) before you invoice.
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