Invoicing outside Spain without getting the VAT wrong
Three questions decide what VAT your invoice carries: whether you sell goods or services, whether your client is a business or a private individual, and whether they are inside or outside the European Union. And one warning: without form 349, the intra-Community exemption falls away.
First things first: Cairos is in Spanish
You can read this page in several languages, but the application you are going to work in is in Spanish only: the menus, the invoices, the tax forms and the help screens. There is no English version and there is still no date for one. Support answers in Spanish too. If you have just arrived in Spain and do not read Spanish comfortably, tell us before you decide: we would rather you knew now than found out on your first day. Our plans and their limits are on pricing.
If you settle in the Basque Country or Navarre, this changes
Álava, Bizkaia, Gipuzkoa and Navarre have their own foral tax regime: you do not file with the state Tax Agency but with their Hacienda Foral, which has its own forms, its own deadlines and its own rates. This page describes the common regime, which is the one that applies in the rest of Spain. And there is one difference worth knowing before any other: in Álava, Bizkaia and Gipuzkoa the invoicing obligation is not VeriFactu, it is TicketBAI, and it is already in force. In Navarre there is no equivalent system approved today. If you are going to settle there, start with that page and talk to an accountant based in that territory.
The right question is not “where is my client”
It is a combination of three things, and until all three are answered you do not know what VAT the invoice carries:
- Are you selling goods or supplying services? They are different rules, and they are nothing alike.
- Is your client a business or professional, or a private individual? That is what changes the answer most.
- Are they in the European Union or outside it?
With those three answers, the table below covers virtually every case an autónomo or a small company will meet.
| What you sell | To whom | What VAT it carries | The regulation |
|---|---|---|---|
| Services | Business in another EU country | Without Spanish VAT. The place of supply is where the customer is established and they declare it under the reverse charge. It goes on form 349. | Arts. 69.One.1 and 84.One.2.a) LIVA |
| Services | Business outside the EU | Without Spanish VAT, under the same place-of-supply rule. It does not go on form 349. | Art. 69.One.1 LIVA |
| Services | Private individual in the EU | With Spanish VAT, as a general rule. There are important exceptions, such as electronically supplied services. | Art. 69.One.2 LIVA |
| Services | Private individual outside the EU | It depends on the service. Those on the list in art. 69.Two do not carry Spanish VAT; the rest do. | Art. 69.Two LIVA |
| Goods | Business in another EU country | Exempt, if the two conditions in article 25 are met. It goes on form 349. | Art. 25.One LIVA |
| Goods | Client outside the EU | Exempt as an export, subject to the requirements set by regulation. | Art. 21 LIVA |
This table leaves out distance sales to private individuals in the EU and electronically supplied services, which have their own rules and their own thresholds. If that is your case, look at the One-Stop Shop and check it with your adviser.
The ROI and VIES: two steps, not one
They are constantly confused, and they are different things.
The ROI, the Register of Intra-Community Operators, is a Spanish register. Being on it is what turns your NIF into an intra-Community VAT number, which is the same number with the ES prefix in front. That is article 25.1 of Real Decreto 1065/2007.
VIES is the European system listing the intra-Community operators of every Member State. It is where you check whether the intra-Community VAT number your German client gave you is actually registered.
You apply to be registered on the ROI
On the census registration declaration itself — article 9.3.g) of Real Decreto 1065/2007 allows it — or later, by a declaration of modification, under article 10.2.e).
You wait, because it is not automatic
The Tax Agency can refuse to assign the number. And article 25.1 warns of something worth knowing: if it does not decide within three months, the requested number may be treated as refused.
You check your client in VIES before invoicing
And you keep the evidence. Having looked it up at some point is not enough: what supports the exemption is that the client was registered on the day of the invoice.
You file form 349
And this is not an incidental formality: on supplies of goods it is a condition of the exemption itself, as the next section shows.
In Cairos, the VIES check is done from the contact's record and saves the date of the check and the reference the European system returns, which is the evidence the exemption rests on if anyone asks. It is available from the free plan, because it is part of the contact record.
The two conditions of an intra-Community supply
This part is explained badly almost everywhere, and it is the one that costs most. Article 25.One of the VAT Act exempts supplies of goods dispatched or transported to the territory of another Member State, provided that:
- That the customer is a business or professional — or a legal person not acting as such — who holds a VAT identification number assigned by a Member State other than Spain, and who has given that number to the seller.
- And — the very next paragraph — applying the exemption is conditional on the seller having included those transactions in the recapitulative return of intra-Community transactions.
Put another way: if you do not file form 349, or if you report that transaction wrongly, the exemption falls away. The 349 is not just another informative return you can leave for another day: it is a condition of the exemption itself. And when the exemption falls away, the VAT is paid by whoever issued the invoice, not by the client.
Two exclusions that are in the same article
The exemption does not apply to supplies made to people whose intra-Community acquisitions are not taxable in the State of destination under the tests in article 14 of the Act. And it does not apply either to supplies under the special regime for second-hand goods, works of art, antiques and collectors' items.
Form 349: monthly by default
It is the recapitulative return on intra-Community transactions, and how often it comes round surprises a lot of people because it does not follow the rhythm of the 303.
Article 81 of the VAT Regulations provides that, as a general rule, it is filed for each calendar month, during the first twenty calendar days of the following month. July's can be filed during August and the first twenty calendar days of September.
The quarterly regime is the exception and comes with a double condition: that neither during the reference quarter nor in each of the four preceding calendar quarters the total cumulative value of the supplies of goods that have to be reported and of intra-Community supplies of services exceeds 50,000 euros, excluding VAT.
And there is a jump rule: if at the end of any of the months making up a calendar quarter that amount is exceeded, a return has to be filed for the month or months elapsed since the start of that quarter, within the following twenty calendar days.
In every case, the return for the last period of the year is filed during the first thirty calendar days of January.
Cairos works out the 349 from each contact's intra-Community VAT number and their invoices, with the codes matching each type of transaction. It comes in from the Autónomo plan upwards, which is €10 a month.
And the currency: what the law says and what Cairos does
If you invoice abroad, sooner or later someone asks for the invoice in their own currency. Spanish law has a specific rule for that.
Article 79.Eleven of the VAT Act says that, in transactions where the consideration has been set in a currency other than the Spanish one, the rate to apply is the selling exchange rate set by the Banco de España in force at the time of the chargeable event. Not the rate on the day you were paid, nor the month's average: the rate at the chargeable event.
This is where Cairos does not reach yet, and it has to be said
Multi-currency is listed as on the way and only on the bespoke plan. Today, on the entry plans, you invoice in euros. If most of what you invoice is in dollars, pounds or Swiss francs, Cairos is not your tool yet. Selling it to you any other way would be exactly what this site deliberately avoids. The plans and what each one includes are on pricing.
What is settled for the client abroad: checking the intra-Community VAT number in VIES from their record, the reverse charge wording on the invoices that require it, the treatment of exports and the quarterly or monthly form 349.
The reverse case: when you are the one paying abroad
It is always forgotten, and it is where the penalties are. When you pay a supplier who is not resident in Spain, the law can turn you into a withholding agent.
That is paid over with form 216 every quarter and summarised on form 296 in January. The hard part is not the arithmetic, it is the rate: the double taxation agreement overrides domestic law, but it can only be applied if the supplier has given you a certificate of tax residence that is in force. Without that piece of paper you withhold at the domestic rate, even when the treaty says zero, and the responsibility is yours.
One nuance that saves you a fright: buying goods from a foreign supplier does not create a withholding. What creates a withholding is certain kinds of income, not any payment abroad.
Cairos works out the 216 and the 296 from the expenses whose supplier has a country other than Spain on their record, and asks about the residence certificate on the screen itself. They come in from the Autónomo plan upwards.
Your client's intra-Community VAT number, checked before you issue
Cairos queries VIES from the contact's record and saves the date and the reference of the check.
Questions about invoicing abroad
How this page is kept up to date
Every figure on this page comes from the consolidated text on the BOE or from the Tax Agency's E-Office, with the legislation cited beside it. What changes every year — the cuota de autónomos, the fees, the bands — is deliberately not reproduced here: an out-of-date figure on a website is worse than no figure at all. Last reviewed: 27 August 2026. If you spot something out of date, write to us at hola@cairos.es.
This is information, not tax or legal advice. The place-of-supply rules have a great many exceptions: for your own case, your tax adviser.
Invoicing abroad is easy when the software knows the rule
VIES from the record, the right wording on the invoice and the period's 349. In euros and in Spanish, which is how the application comes today.
Forms from the Autónomo plan · Multi-currency not yet · No minimum term