Autónomo with foreign clients: VAT, invoices, ROI, form 349 and IRPF based on your client's location
Last updated 14 October 2026 · Reviewed by Jaime Piñeira Pardo, lawyer registered with the ICAM bar, no. 138826 · English version of our Spanish guide.
The short answer
Autónomo with foreign clients: you invoice a company in another country, whether EU or non-EU, without Spanish VAT, because the service is not subject to VAT in Spain (it is not exempt). With the EU, you add registration in the ROI and form 349. As a general rule, you charge VAT to an EU individual. And if no one withholds tax, you submit form 130.
We handle the whole procedure for you, from start to finish.
You describe your case in a chat and sign; we file it with the Spanish authorities. Fixed price from €180.00 (21% VAT included), plus the tasa (official fee) where there is one.
What is new, and the law that applies
- 3 February 2025: form 037 disappears (Orden HAC/1526/2024). All census registrations, modifications or deregistrations, including ROI registration, go with form 036.
- 2 December 2025: Real Decreto-ley 15/2025 sets the Verifactu deadlines: before 1 January 2027 for Corporate Tax payers and before 1 July 2027 for the rest, including autónomos.
- 2026: the 2026 form 303 instructions (updated on 9 June 2026) assign services to EU companies to box 59, those not subject outside the EU to 120 and those under the ventanilla única (one-stop shop) to 123.
- Since 2020, form 349 no longer has an annual frequency: only monthly or quarterly.
Does an invoice to a foreign client include VAT?
It depends on who your client is and where they are located. The Ley del IVA (the Spanish VAT Act, art. 69) establishes where a service is provided: if the client is a business or professional, it is where their headquarters or establishment is located. Therefore, you invoice a company established outside Spain without Spanish VAT, whether it is in Germany or the United States.
If the client is an individual, the rule is reversed: the service is located where you are, and as a general rule you charge Spanish VAT, whether the individual lives in Madrid, Lisbon or Toronto. There are 2 main exceptions: certain services to non-EU individuals (art. 69.Dos) and electronic, telecommunications and broadcasting services to individuals in other EU countries when a limit is exceeded (art. 70.Uno.8.º).
Pay attention to the vocabulary: a service to a foreign company is not "exempt", it is "not subject" to Spanish VAT. Each case goes to a different box on form 303 and carries a different mention on the invoice.
This guide covers standard freelance services (consulting, design, programming, translation, marketing). Those related to real estate in Spain, passenger transport or events held here follow special rules (art. 70).
How do you invoice an EU company with the reverse charge mechanism?
The invoice goes without Spanish VAT and it is your client who declares the VAT in their country. This is the reverse charge mechanism, which operates in the client's country. The Reglamento de Facturación (the Spanish invoicing regulations, RD 1619/2012, art. 6.1.m) requires that, when the taxpayer is the recipient, the invoice must include the mention "inversión del sujeto pasivo" (reverse charge).
Before the first invoice, check that your client is genuinely a company: ask for their intra-community VAT number and verify it in the European Commission's VIES system. Keep the search result with the invoice. The invoice must show your NIF-IVA (your tax identification number with the ES prefix) and your client's.
3 obligations accompany these invoices. The first is registration in the Registry of Intra-Community Operators (ROI), which is requested using form 036 by ticking box 582 and indicating the expected date of the first operation in box 584. The AEAT (the Spanish tax agency, also known as Hacienda) has 3 months and its silence means a negative response: request it with plenty of time. What makes the service not taxable in Spain is that your client is a company in another State, not the ROI, but registration is mandatory anyway.
The second is declaring the amount on form 303, in box 59 (intra-community provision of services for the period), according to the 2026 AEAT instructions. And the third is form 349, the recapitulative statement of intra-community operations, where each service to an EU company is declared with the key S, the client's NIF-IVA and the amount.
How do you invoice a non-EU company, for example in the US?
Also without Spanish VAT, and for the same reason: the recipient is a business established outside Spain (art. 69.Uno.1.º). However, there is no form 349, because it is not an intra-community operation, nor is there ROI registration for this reason.
On form 303, the amount goes to box 120, for operations not subject due to location rules. It does not go to box 60, for exports and assimilated operations. On the invoice, it is advisable to indicate that the operation is not subject to Spanish VAT due to the application of location rules. Do not write "exempt".
Outside the EU there is no VIES: keep the contract, the company's registration details and tax number, and address the invoice to the company. This is your proof that the service was not subject.
What VAT applies to an invoice for an EU or non-EU individual?
As a general rule, you invoice an individual in another EU country with Spanish VAT (art. 69.Uno.2.º).
The exception is services provided electronically, telecommunications and broadcasting. Electronic services include, among others, web hosting, the supply of software, texts or databases, and distance learning (art. 69.Tres.4.º). Sending work by email does not make it an electronic service: the law itself states this.
These services to individuals in other EU States are taxed in Spain as long as the limit in art. 73 of the law is not exceeded and you do not opt to be taxed at the destination. The limit is €10,000 without VAT, adding these services and distance sales of goods to the entire EU, and the 2 years count: if you exceeded it the previous year, or from the moment you exceed it in the current year, it is taxed in the client's country. Above this, or if you opt for it, the VAT of the client's country applies, which you can declare in the ventanilla única (one-stop shop, form 369, quarterly). On form 303, these operations go to box 123.
For a non-EU individual, only the services listed in art. 69.Dos go without Spanish VAT: among others, the transfer of copyright and intellectual property, advertising, advice, consulting, engineering, legal services, accounting or tax services, data processing, translation and text correction. And with 2 limits: the individual cannot be in the Canary Islands, Ceuta or Melilla, and the service cannot be used or exploited in Spain (art. 70.Dos). Any other service to a non-EU individual includes Spanish VAT, except for electronic, telecommunications and broadcasting services, which follow special rules (art. 70) that this guide does not cover.
Do I have to submit form 130 if my clients are foreign?
Very likely, yes. If your activity is professional, a Spanish company withholds 15% (7% in the starting year and the following 2). On your invoices to foreign clients, this withholding normally does not appear.
The AEAT rule is this: the professional does not submit form 130 if in the previous calendar year at least 70% of their professional income had withholding applied. In the first year, that 70% is measured over the instalment payment period. If the majority of your invoicing goes to foreign clients without withholding, you do not reach 70% and you have to submit form 130 every quarter.
Form 130 pays 20% of the accumulated net yield since 1 January (income minus deductible expenses), subtracting what was paid in previous quarters and any withholdings that have been applied to you. In the income tax return (form 100), these payments are deducted.
If you are a tax resident in Spain (more than 183 days of the year here, or the core of your activities or interests in Spain), what you earn from foreign clients is declared in your IRPF (personal income tax) like any other income from the activity.
Can I invoice and get paid in dollars or another currency?
Yes. The Reglamento de Facturación (RD 1619/2012, art. 12) allows amounts to be expressed in any currency and the invoice to be issued in any language. The only condition is that, if the invoice includes Spanish VAT, the tax amount must appear in euros, using the exchange rate referred to in art. 79.Once of the Ley del IVA.
Your tax returns, on the other hand, are always in euros: form 303, form 349, form 130 and the income tax return. Keep the exchange rate you applied and the amount that actually entered your account with each invoice. The bank or platform commission and the exchange difference are reflected in your accounting.
Furthermore, from 1 July 2027, your invoicing software must comply with Verifactu: Real Decreto-ley 15/2025 requires it to be adapted before 1 January 2027 for Corporate Tax payers and before 1 July 2027 for all other obligated parties, including autónomos.
What changes if I am a self-employed digital nomad?
If you reside in Spain, you invoice and file taxes like any autónomo (self-employed worker). But your international teleworking residence authorisation adds a limit: as a professional, you can work for Spanish companies provided they do not exceed 20% of your total activity (art. 74 bis.1 of Ley 14/2013, the Spanish Entrepreneurs Act). Invoicing more to Spanish clients puts your authorisation at risk.
Invoices to that Spanish client, within the 20%, include Spanish VAT and, if your activity is professional, withholding. Keep track by client and by country from the first invoice to be able to prove the 20%.
Since you work on a self-employed basis regularly, personally and directly, you must be registered in the RETA (the special regime for self-employed workers of the Seguridad Social, the Spanish social security system, art. 305.1 of the Ley General de la Seguridad Social), unless you are covered by the social security of a country with an agreement with Spain and have your certificate of coverage. And a warning about the régimen de impatriados (impatriate regime or Ley Beckham): its teleworking route requires an employment relationship, so a nomad invoicing as an autónomo does not qualify through that route. We explain this in our guide to the impatriate regime.
How does Managora help you with your foreign clients?
With Managora's Self-employed plan, you do not need to know any of this. For a fixed monthly fee, we handle your forms 303 and 390, your 130 and your income tax return, ROI registration and form 349 if you operate with the EU, and your accounting from a photo of your invoices. You can see the updated price on the plans page.
You issue your invoices with your software and we review them: the one without VAT to a foreign client is not entered at 21%, it goes to its specific box on form 303, and the one for an EU company goes into form 349. We never submit a tax return without your approval.
We submit forms 036, 303, 130, 349, 390 and 100 to the AEAT using the mandate you sign, because the firm's lawyer is a social collaborator of the Tax Agency. We never ask for your digital certificate. We submit your RETA registration through the Sistema RED, without you having to log into any electronic headquarters.
If you only need a single procedure (autónomo registration, form 036, 303, 130, 349, the ventanilla única (one-stop shop) or the income tax return), each one has its own page, where you can see the updated amount.
Step by step
- 1
Register with Hacienda using form 036(Before starting the activity)
With EU corporate clients, tick box 582 (ROI registration) on the same form 036 and the date of the first operation in box 584.
- 2
Register in the RETA(On the start date or up to 60 days before)
If you are entitled to the flat rate (initial registration, or no registration in the previous 2 years, or in the previous 3 if you already enjoyed it), request it during the registration itself, which is when the law says it must be requested (art. 38 ter.3 of the LETA).
- 3
Classify each client before invoicing(Before the first invoice to that client)
Company or individual; in Spain, in the EU or outside. If it is an EU company, check its NIF-IVA in VIES.
- 4
Issue the invoice with the correct mention(With each operation)
Inversión del sujeto pasivo (reverse charge, EU company), not subject due to location rules (non-EU company) or Spanish VAT (individual, with exceptions).
- 5
Submit form 303 with each amount in its box(1 to 20 April, July and October; 1 to 30 January)
Box 59 for services to EU companies, 120 for those not subject outside the EU and 123 for those under the ventanilla única (one-stop shop).
- 6
Submit form 349 if you invoice EU companies(Same deadlines as form 303 if quarterly)
1 line per client, with their NIF-IVA, key S and the amount.
- 7
Submit form 130 if your income has no withholding(Every quarter)
If less than 70% of your income had withholding applied: 20% of the accumulated net yield.
- 8
Close the year with form 390 and the income tax return(Form 390 in January; income tax return during its campaign)
Form 390 summarises the VAT for the year; form 130 payments are deducted in the income tax return.
A worked example
You are a marketing consultant, resident in Spain and registered since 1 October 2026. In the 4th quarter you issue 2 invoices: €3,000 to a GmbH in Berlin and 2,000 dollars to an Inc. in New York. Your deductible expenses for the quarter total €900. The exchange rate of €0.90 per dollar is an assumption for the example.
- Invoice to Germany: €3,000 without VAT, with the mention "inversión del sujeto pasivo" and the German NIF-IVA verified in VIES. Beforehand, ROI registration.
- Invoice to the US: 2,000 dollars without VAT, indicating that the operation is not subject due to location rules. In euros: 2,000 x 0.90 = €1,800.
- Form 303 for the 4th quarter (1 to 30 January 2027): €3,000 in box 59 and €1,800 in box 120.
- Form 349 for the 4th quarter (1 to 30 January 2027): one line with the German NIF-IVA, key S and €3,000.
- Form 130: neither invoice had withholding applied, so you do not reach 70% and you submit it. Net yield: 3,000 + 1,800 - 900 = €3,900. Payment: 3,900 x 20% = €780, before any reductions that may apply in the form itself.
Neither of the 2 invoices includes Spanish VAT, but each goes to a different box on form 303 and only the German one goes into form 349. Form 130 results in a payment of at most €780 because your clients do not withhold tax from you.
How each professional service is invoiced depending on the client (2026)
| Client | Spanish VAT? | Who declares the VAT | What the invoice indicates | Form 303 box | Form 349 and ROI |
|---|---|---|---|---|---|
| Company or professional in Spain | Yes (art. 69.Uno.1.º) | You, on your form 303 | VAT at the corresponding rate and, if professional, 15% withholding (7% at the start) | Accrued VAT (IVA devengado) | No |
| Company in another EU country | No: not subject (art. 69.Uno.1.º) | The client, in their country | "Inversión del sujeto pasivo" and the NIF-IVA of both | 59 | Yes: form 349 with key S and ROI registration |
| Individual in another EU country | Yes, as a general rule (art. 69.Uno.2.º) | You, on your form 303 | Spanish VAT | Accrued VAT (IVA devengado) | No |
| EU individual, electronic services over €10,000 | No: VAT of the client's country (art. 70.Uno.8.º) | You, in the ventanilla única (one-stop shop, form 369) | VAT of the client's country | 123 | No |
| Non-EU company | No: not subject (art. 69.Uno.1.º) | No one in Spain | Operation not subject due to location rules (never "exempt") | 120 | No |
| Non-EU individual, service under art. 69.Dos not used or exploited in Spain | No: not subject (art. 69.Dos and 70.Dos) | No one in Spain | Operation not subject due to location rules | 120 | No |
| Non-EU individual, any other service (except electronic, telecommunications and broadcasting) | Yes (art. 69.Uno.2.º) | You, on your form 303 | Spanish VAT | Accrued VAT (IVA devengado) | No |
Calendar for an autónomo with foreign clients
| Form | What it declares | Deadline |
|---|---|---|
| 303 (quarterly) | VAT for the quarter (boxes 59, 120 and 123) | 1 to 20 April, July and October; 4th quarter, 1 to 30 January |
| 349 (quarterly) | Services to EU companies (key S), up to €50,000 per quarter in that and the previous 4 | 1 to 20 April, July and October; 4th quarter, 1 to 30 January |
| 349 (monthly) | Same, when €50,000 is exceeded | Month by month |
| 130 (quarterly) | 20% of the accumulated net yield | Up to 20 April, July and October; 4th quarter, in January |
| 369 (quarterly) | Ventanilla única (OSS one-stop shop) | Up to the last day of the month following the quarter |
| 390 (annual) | Annual VAT summary | 1 to 30 January of the following year |
| 100 (annual) | Income tax return | Income tax campaign of the following year |
EU company or non-EU company: what changes
| EU company (for example, Germany) | Non-EU company (for example, US) | |
|---|---|---|
| Spanish VAT? | No, not subject | No, not subject |
| Who declares the VAT | The client, in their country | No one in Spain |
| Mention on the invoice | "Inversión del sujeto pasivo" | Not subject due to location rules |
| Form 303 box | 59 | 120 |
| Form 349 | Yes, with key S | No |
| ROI registration | Yes, before the first invoice | No for this reason |
| How to verify it is a company | NIF-IVA in VIES | Contract and company registration details |
| IRPF withholding on the invoice | Normally no | Normally no |
Official forms and where it is filed
- Form 303: 2026 instructions (AEAT) ↗
- Form 349: recapitulative statement of intra-community operations (AEAT) ↗
- Form 349: submission deadlines (AEAT) ↗
- Form 130: IRPF instalment payments (AEAT) ↗
- Form 369: ventanilla única (OSS one-stop shop, AEAT) ↗
- VAT ventanilla única (one-stop shop) guide (AEAT) ↗
- VIES: NIF-IVA verification (European Commission) ↗
- Verifactu: note on the deadline extension (AEAT) ↗
Frequently asked questions
How do you issue an invoice without VAT to a foreign client?
If the client is a company established outside Spain, it goes without Spanish VAT. If it is from the EU, add the mention "inversión del sujeto pasivo" and the NIF-IVA of both parties; if it is from outside the EU, indicate that the operation is not subject due to location rules.
Do I need ROI registration to invoice an EU company?
You must be registered, but this is not what makes the invoice go without VAT: that depends on your client being a company in another State. It is requested with form 036 before the first operation; the AEAT has 3 months and its silence means a negative response.
Do my services to a US client go on form 349?
No. Form 349 only includes intra-community operations. A service to a US company goes to box 120 of form 303.
Is an exempt operation the same as a non-subject one?
No. A service to a foreign company is not subject: the law locates it outside Spain. It goes to a different box on form 303 than exempt operations, and you must not write "exempt" on the invoice.
If my clients do not withhold IRPF, what do I have to do?
Submit form 130 every quarter if in the previous year less than 70% of your professional income had withholding applied (the first year is measured over the period itself). You pay 20% of the accumulated net yield.
Can I invoice in dollars as an autónomo in Spain?
Yes, the invoice can be in any currency and in any language. If it includes Spanish VAT, the tax amount must appear in euros. Keep the applied exchange rate: your tax returns are filed in euros.
We handle the whole procedure for you, from start to finish.
You describe your case in a chat and sign; we file it with the Spanish authorities. Fixed price from €180.00 (21% VAT included), plus the tasa (official fee) where there is one.
Related procedures
The price, the tasa (official fee) and the current deadlines are on each procedure page.
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Self-employed plan: your taxes, every quarter, without thinking about them
VAT and income tax, form 349 if you invoice EU clients, registrations, your tax calendar and bookkeeping from a photo of each invoice, for a monthly fee.
See the plans →Related guides
- Registering on the ROI: the intra-community NIF-IVA and the VIES census
- VAT for the self-employed in Spain: modelo 303 and modelo 390
- IRPF for the self-employed in Spain: payments on account and withholdings
- Registering as a freelancer: Hacienda and Seguridad Social
- Tax residence certificate and W-8BEN form
- E-commerce VAT: the One Stop Shop OSS/IOSS (modelo 369)
- Digital nomad visa in Spain 2026: requirements, minimum income and how to apply (consulate or UGE)
- Remote working from Spain for a foreign company
- Self-employment in Spain as a foreigner: freelance visa, digital nomad or entrepreneur, which one is for you
- Reverse charge mechanism: the invoice without VAT
- Deferred import VAT: how to avoid paying it at customs
- Form 037: the simplified census registration vs form 036
- The IPSI: selling, buying or invoicing in Ceuta and Melilla
- 401(k), IRA and Roth IRA for a resident in Spain
- Autónomo societario: classification, RETA registration and fee
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