How to invoice a client in France from Spain (2026)
A 2026 guide for Spain-based freelancers billing France: reverse charge, ROI registration, VIES validation, Modelo 349 and OSS, step by step.
TL;DR: When you bill a service to a French company from Spain, the operation is located in France (art. 69.Uno.1º of Law 37/1992): you issue the invoice with no Spanish VAT and your French client self-assesses the tax under the reverse charge. To make it valid you must be registered on the ROI, validate the French VAT number in VIES, and report the sale in Modelo 349 under code S.
Key takeaways
- A B2B service to a French company is not subject to Spanish VAT: it is located where the client is (art. 69.Uno.1º of Law 37/1992). You invoice with 0% VAT and the French client accounts for the tax under the reverse charge.
- The invoice must carry the literal note «inversión del sujeto pasivo» (reverse charge), required by art. 6.1.m) of Royal Decree 1619/2012 (the invoicing regulation).
- Before you issue: register on the ROI via Modelo 036 (box 582, plus the expected first-operation date in box 584). The tax agency has 3 months to respond, and silence counts as denial. Then validate the client’s French VAT number in VIES.
- You report the operation in Modelo 349 under code S (services). It is quarterly by default, or monthly if your combined intra-EU operations exceed €50,000 (VAT excluded).
- With a French private consumer (B2C) there is no reverse charge: the single EU-wide €10,000 threshold applies (art. 73 of Law 37/1992) and, once passed, you charge French VAT and can use the One-Stop Shop (OSS) with Modelo 035 and Modelo 369.
Contents
You have just landed a French client, the first invoice is half-written on your screen, and you are stuck on one field: VAT. Here is the short answer. If you are billing a service to a French company from Spain, you issue the invoice with no Spanish VAT, and your client accounts for the VAT in France instead. The reason is that a service supplied to a business or professional established in another EU member state is located where the client is — France — under the general rule in article 69.Uno.1º of Law 37/1992, so it is not subject to Spanish VAT. That mechanism is the reverse charge (in Spanish, inversión del sujeto pasivo). To make it valid you have to clear three prerequisites that are not optional: register on the ROI, validate your client in VIES, and report the operation in Modelo 349. This guide walks through all three, in order.
The rule that changes everything: the service is located in France
Intra-EU VAT runs on one principle: for business-to-business services, the tax is due in the client’s country, not the supplier’s. When a Spanish freelancer or company supplies a service to a French company, that service is deemed to take place in France and carries no Spanish VAT.
This is not a loophole or a tax break — it is how Directive 2006/112/CE is designed, transposed into Spain’s VAT Law (art. 69 for the place of supply of services). In practice:
- You do not charge VAT on the invoice.
- Your French client self-assesses the VAT in France, applying French rules and rates through the reverse charge.
- You keep the right to deduct the input VAT you paid to provide that service, even though the invoice carries no output VAT.
This applies to services of every kind: consulting, design, development, marketing, recorded training, professional services. Supplies of goods follow their own rules — we cover those below — but the administrative circuit (ROI, VIES and Modelo 349) is the same. For the mechanism itself, see our reverse charge guide.
Before the first invoice: ROI and VIES
Here is the most expensive mistake beginners make: issuing the VAT-free invoice before the paperwork is in place. Do it without being on the ROI or without validating the client, and the operation fails the conditions for non-subjection — the tax agency can then demand the VAT you did not charge, plus surcharges and interest.
1. ROI registration (Register of Intra-Community Operators). You request it through the census declaration, Modelo 036, ticking box 582 (registration request) and entering the expected date of your first operation in box 584. On registration, the tax agency assigns you a VAT number and lists you in VIES. Mind the timing: the agency has up to 3 months to resolve, and if it lets that period lapse without answering, the request is treated as denied. Ask for it with margin, not the night before you invoice. The step-by-step process is in our Modelo 349 and ROI registration guide.
2. Validating the client in VIES. Before you issue, check in VIES that your French client’s VAT number (prefix FR) is valid and active. Running the check from the AEAT portal requires an electronic certificate or electronic ID. In practice, without a valid VAT number you cannot justify the non-subjection: if the client does not give you a valid VAT number, you cannot treat the operation as an intra-EU non-subject supply and would have to charge Spanish VAT. Keep the dated proof of every check — it is your evidence in an audit. Our VIES validation guide covers the details.
How to issue the invoice to France
An invoice to your French client looks like a Spanish one, with two key differences: no VAT line, plus one mandatory legal note.
It must include:
- Your VAT number and the client’s French VAT number (prefix FR + their digits).
- The taxable base, with no VAT amount.
- The literal note «inversión del sujeto pasivo» (reverse charge), required by art. 6.1.m) of Royal Decree 1619/2012 (the invoicing regulation). It documents that the party liable for the tax is the recipient. You can pair it with a reference to Directive 2006/112/CE (art. 196), the source of the recipient’s reverse-charge liability. Art. 6.1.j) of the regulation is reserved for exempt operations —e.g. intra-EU supplies of goods—, not a service that is non-subject by place of supply.
A worked example
A freelance developer in Seville invoices a web project to a startup in Lyon for €4,000. He is already on the ROI and has validated the startup’s French VAT number in VIES. His invoice:
| Item | Amount |
|---|---|
| Taxable base (web development) | €4,000.00 |
| Spanish VAT (21%) | — not charged |
| Invoice total | €4,000.00 |
| Mandatory note | «Inversión del sujeto pasivo» (art. 6.1.m RD 1619/2012) |
The Lyon startup receives the €4,000 invoice, with no Spanish VAT, and self-assesses French VAT in its own return. The developer collects the full €4,000 with no VAT — but that income still forms part of his income tax base (personal IRPF, or corporate tax if the issuer is a company): a VAT-free invoice does not mean tax-free income. An invoice to a French client also carries no IRPF withholding, because a non-resident client is not a withholding agent for Spanish income tax.
Goods or services: non-subject vs. exempt
One distinction worth keeping straight: not everything you invoice without VAT is classified the same way.
- A B2B service to a French company is not subject to Spanish VAT, because it is located in France (art. 69.Uno.1º of Law 37/1992).
- A supply of goods to a French company with a valid VAT number, transported to France, is an exempt intra-community supply (art. 25 of Law 37/1992).
In both cases the invoice goes out with no Spanish VAT, but the legal classification and what you report differ. For goods, the invoice carries a reference to the exemption (art. 6.1.j of RD 1619/2012), not the reverse-charge note. And in Modelo 349 you use a different code: E for intra-community supplies of goods, S for intra-community supplies of services. Confusing “non-subject” with “exempt” does not change what you collect, but it does change whether the invoice and the 349 are formally correct.
Modelo 349: when and how often
Each service supplied to a business client in another member state is reported in Modelo 349, the recapitulative declaration of intra-community operations. The persons obliged to file are the VAT taxpayers who carry out the operations listed in article 79 of the VAT Regulation (Royal Decree 1624/1992). It is an informational return: it generates no payment, it just cross-checks data between EU tax administrations. A service to your French client is reported under code S.
The frequency depends on a threshold: €50,000 (VAT excluded) across combined intra-community supplies of goods plus services. If neither the reference quarter nor any of the previous four calendar quarters exceeds that figure, you file quarterly; once it is exceeded, you switch to monthly. The deadlines:
| Period | Filing deadline |
|---|---|
| Monthly (general rule) | The first 20 calendar days of the following month |
| Month of July | During August and the first 20 days of September |
| December / Q4 | The first 30 calendar days of January |
| Quarterly (other quarters) | The first 20 calendar days of the following month |
On your quarterly Modelo 303, these supplies are also reflected as an operation not subject under place-of-supply rules with the right to deduct: they do not change the amount payable, but they must reconcile with what you reported in the 349. If you split your work between Spain and the EU, it helps to review how it all fits together in our quarterly VAT guide for freelancers billing the EU.
B2B vs. B2C: when the OSS comes in
Everything above assumes your French client is a business or professional with a VAT number. If you invoice a French private consumer (B2C), the circuit is different: there is no reverse charge.
For distance sales of goods and for digital services (telecommunications, broadcasting and electronic services), a single €10,000 threshold (VAT excluded) applies across the whole EU, set out in article 73 of Law 37/1992. Below it, you charge Spanish VAT; above it, you tax in the country of consumption — France, at the French rate — and can declare it through the One-Stop Shop (OSS): register for the scheme with Modelo 035 and file periodic returns with Modelo 369 (quarterly under the Union scheme). The OSS spares you from registering for VAT country by country.
| B2B (French company) | B2C (French consumer) | |
|---|---|---|
| VAT on the invoice? | No (reverse charge) | Depends on the threshold |
| Relevant threshold | €50,000 → Modelo 349 frequency | €10,000 → taxation at destination |
| Who settles the VAT | The client, in France | You, in France (via OSS) or in Spain |
| Return | Modelo 349 (code S) | OSS: Modelo 035 (registration) + 369 (quarterly) |
If you sell products or digital services to consumers, the detail is in our EU VAT on digital services and the OSS guide. And if your work includes clients outside the EU, the treatment changes again: we cover it in the exporting services outside the EU guide.
An important warning if you invoice from the Canary Islands
This circuit — ROI, VAT-free invoice, Modelo 349 — is built for businesses established in the mainland or the Balearic Islands, which is the Spanish VAT territory. The Canary Islands, Ceuta and Melilla are outside it. The Canaries apply IGIC and, for EU VAT purposes, the archipelago counts as third territory, so the intra-EU VAT rules do not work the same way as on the mainland.
If you invoice from the Canaries, do not take this guide’s instructions at face value: an operation with France may follow the logic of a third-country operation rather than the intra-EU one. This is a critical point, and worth confirming with your adviser before you bill.
Common mistakes when invoicing France
How Frihet automates it
Invoicing France adds steps that are easy to forget when you run the paperwork by hand. With Frihet you issue the invoice already with no Spanish VAT and the reverse-charge note built in, and the operation is flagged as intra-community so the Modelo 349 data — with its code S — is ready when it is time to file, along with the correct reflection on your Modelo 303. Frihet calculates and prepares the return from your invoices and expenses, handling the VAT, IGIC and IRPF treatment your activity needs, VeriFactu included, with OCR expense capture and a real-time financial dashboard behind it.
What Frihet does not do for you: ROI registration and filing the 349 are still steps you or your adviser complete with the tax agency. What it does prevent is an invoice going out with a formal error, or an EU sale left unreconciled. Everything else — who settles the tax, with what note, in which return — stops depending on your memory.
Invoicing a client in France is not complicated: it is routine once you have the ROI, validate the client, and know which note to add. The first send costs a little more; from the second on, it is a two-minute task.
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FAQ
Do I charge VAT to my French client?
No, if it is a business or professional with a valid VAT number. The service is located in France under the general rule of art. 69.Uno.1º of Law 37/1992, so you issue the invoice with no Spanish VAT and your client self-assesses French VAT under the reverse charge. If the client is a private consumer (B2C), the treatment is different.
What do I need before issuing my first invoice to France?
Two prerequisites: being registered on the ROI (Register of Intra-Community Operators) via Modelo 036, so you appear in VIES; and validating your French client’s VAT number in VIES before invoicing. Without both, the operation cannot be treated as an intra-EU non-subject supply.
What note must the invoice carry?
The literal note «inversión del sujeto pasivo» (reverse charge), required by art. 6.1.m) of Royal Decree 1619/2012. It documents that the party liable for the VAT is your French client, not you. Without it, the invoice breaches the regulation even if the underlying figures are correct.
How often do I file Modelo 349?
Quarterly by default, using code S for intra-community services. It switches to monthly if your intra-EU operations (goods plus services) exceed €50,000 excluding VAT. The general monthly deadline is the first 20 calendar days of the following month, with special rules for July and for December or Q4 (the first 30 days of January).
What changes if I sell goods instead of services?
The classification changes. A B2B intra-EU service is «not subject» to Spanish VAT; a supply of goods to a French company transported to France is an intra-community «exempt» supply (art. 25 of Law 37/1992). In both cases you invoice with no Spanish VAT, but the invoice note and the Modelo 349 code differ (S for services, E for goods).
Does anything change if I invoice from the Canary Islands?
Yes, significantly. The Spanish VAT territory is the mainland and the Balearic Islands; the Canary Islands, Ceuta and Melilla are outside it. The Canary Islands apply IGIC and, for EU VAT purposes, count as third territory, so the intra-EU ROI and Modelo 349 rules do not work the same way. If you invoice from the Canaries, check your specific case with your adviser before billing.
