How to invoice a German client from Spain (2026)
A Spain-based freelancer's guide to billing a German company: no Spanish VAT, the reverse-charge note, VIES validation, ROI registration, modelo 349 and OSS.
TL;DR: A B2B service billed by a Spain-based freelancer or company to a German business is located where the client is (art. 69.Uno.1º of Law 37/1992): you issue the invoice with no Spanish VAT and the "reverse charge" note, and the German client self-assesses the Umsatzsteuer in Germany. You need both parties' VAT numbers valid in VIES, ROI registration via modelo 036, and to report the operation on modelo 349. Selling to German consumers (B2C) is a different regime: the One-Stop Shop (OSS) with a common EUR 10,000 threshold.
Key takeaways
- Under the general place-of-supply rule (art. 69.Uno.1º of Law 37/1992), a B2B service billed to a German company is located in Germany — no Spanish VAT on the invoice.
- The invoice carries no VAT and must include the mandatory "reverse charge" note («inversión del sujeto pasivo», art. 6.1.m of RD 1619/2012); the client self-assesses the Umsatzsteuer in Germany under art. 196 of Directive 2006/112/EC (transposed as §13b UStG).
- Before you invoice, register in the ROI via modelo 036 (box 582) and make sure both parties have a valid VAT number verifiable in VIES; yours is "ES" + your tax ID.
- Report the operation on modelo 349 (Order EHA/769/2010): monthly by default, or quarterly if you stay under EUR 50,000 (VAT excluded) this quarter and the four previous ones.
- OSS and its EUR 10,000 (VAT excluded) threshold apply to sales to final consumers (B2C): below it you charge at origin (Spanish VAT), above it at destination (German VAT), filing everything through the one-stop shop.
Contents
You have landed a German client, agreed the scope and the rate, and then the first invoice stalls on the VAT line. Short answer: there is no VAT line. A Spain-based freelancer or company billing a business client in Germany for a service issues the invoice with no Spanish VAT and adds the reverse-charge note. Under the general place-of-supply rule (art. 69.Uno.1º of Law 37/1992), a B2B service is located where the client is established — Germany — so you do not charge VAT: the client self-assesses the Umsatzsteuer (German VAT) under the reverse-charge mechanism. To do it cleanly you need three things: a VAT number valid in VIES on both sides, ROI registration via modelo 036, and the operation reported on modelo 349. The OSS regime and its EUR 10,000 threshold only come into play when you sell to German consumers, not to companies.
Why the invoice carries no Spanish VAT
Start with the place-of-supply rule. For services between businesses (B2B), VAT is paid at destination, not at origin. Article 69.Uno.1º of Law 37/1992 sets it out: a service supplied by a Spanish business to a business established in another member state is deemed to take place at the recipient’s location. If the recipient is a German company, the operation is located in Germany and is not subject to Spanish VAT.
This is not a loophole. It is how the EU’s common VAT system is designed: the country where the service is consumed is the one that collects the tax, and the reverse-charge mechanism is what makes that work across borders.
Reverse charge: who accounts for the VAT
When the supplier is not established in the country where the operation is taxed, the taxable person becomes the recipient — this is the reverse charge mechanism. You, the Spanish supplier, invoice without VAT, and the German company self-assesses the Umsatzsteuer in Germany at whatever rate applies there, under art. 196 of Directive 2006/112/EC (transposed in Germany as §13b UStG). Article 84.Uno.2º of Law 37/1992 governs the equivalent mechanism on the Spanish side, for the mirror case (a Spanish business receiving the service).
The practical effect for you is simple: the invoice goes out at zero VAT, and the amount you collect is the net value of your work. You also keep the right to deduct the input VAT on purchases tied to that activity, even though your output invoice carries no VAT. For the full mechanics on the Spanish side, see our guide to the reverse-charge mechanism.
Before you invoice: ROI registration and VIES
Two prerequisites, both non-negotiable:
- Register in the ROI (Register of Intra-Community Operators). To trade VAT-free with EU businesses you need a VAT number, obtained by applying for ROI registration through modelo 036 (the census declaration): tick box 582 to request registration and state the expected date of your first operation in box 584 (box 583 is for de-registration). Being assigned the VAT number means being added to the VIES census. Your VAT number is
ES+ your tax ID (the country prefix follows the ISO 3166 alpha-2 standard), and it must appear on your invoices. Mind the timing: the tax authority has up to 3 months to decide and, if it does not, the request can be treated as denied by silence. Start early. - Validate the client’s VAT number in VIES. Before you invoice, check that your client’s German VAT number (
DEprefix) is valid in the VIES census (the VAT Information Exchange System). If the client does not have a valid VAT number, you cannot treat the operation as a B2B intra-community supply.
How to build the invoice, field by field
An invoice to Germany is almost identical to a domestic one, with three differences:
| Field | Domestic invoice | Invoice to a German company |
|---|---|---|
| VAT rate | 21% / 10% / 4% | No VAT (out of scope) |
| VAT amount | Calculated | EUR 0.00 |
| Legal note | Not required | «Inversión del sujeto pasivo» |
The reverse-charge note — «inversión del sujeto pasivo» — is mandatory when the taxable person is the recipient (art. 6.1.m of the invoicing regulation, RD 1619/2012). Keep the note in Spanish so it maps directly to the Spanish legal reference; you can add an English gloss (“reverse charge”) alongside it. The invoice must also carry your Spanish VAT number and the client’s German VAT number, each with its country prefix.
Worked example
A Spanish developer bills 30 hours of work to a company in Berlin at EUR 90/hour:
| Item | Amount |
|---|---|
| Software development (30 h × EUR 90/h) | EUR 2,700.00 |
| Taxable base | EUR 2,700.00 |
| VAT (out of scope — reverse charge) | EUR 0.00 |
| Total to collect | EUR 2,700.00 |
Supplier VAT no.: ES12345678A · Client VAT no.: DE123456789 Out of scope by place of supply (art. 69.Uno.1º Law 37/1992). Reverse charge.
The German client receives EUR 2,700 and accounts for the Umsatzsteuer in its country. You remit no VAT on this operation — but you do report it on modelo 349.
The exception: article 70 services
The general destination rule has exceptions. Article 70 of Law 37/1992 sets special rules for certain services that are located where the property or event is, not where the client resides. The most common cases:
- Services connected to immovable property located in Spain (construction, renovation, management or valuation of a property in Spanish territory).
- Admission to events — cultural, artistic, sporting, fairs or conferences.
- Restaurant and catering services physically carried out in a specific place.
If your service to the German company falls under article 70, the location can change and the destination rule does not automatically apply. When in doubt, check before you issue: Spain’s tax authority offers a “service place-of-supply locator” tool to guide you, but the VAT treatment on the invoice depends on getting this right.
Modelo 349: when and how to file
Every intra-community supply of services located at destination is reported on modelo 349, the recapitulative statement of intra-community operations (approved by Order EHA/769/2010). It is an informational return: it pays nothing, it simply tells the tax authority what you have billed to operators in other EU countries so the data can be cross-checked against what they declare. Every business or professional carrying out intra-community operations must file it, whatever their VAT regime.
Frequency depends on volume:
| Situation | Frequency |
|---|---|
| Intra-community supplies of goods and services > EUR 50,000 (VAT excluded) in the current quarter or any of the previous 4 | Monthly |
| All other cases | Quarterly |
If you cross EUR 50,000 mid-quarter, you switch to monthly filing. The deadlines in force in 2026:
| Period | Filing deadline |
|---|---|
| Monthly | The first 20 calendar days of the following month |
| Q1 (Jan–Mar) | 1–20 April |
| Q2 (Apr–Jun) | 1–20 July |
| Q3 (Jul–Sep) | 1–20 October |
| Q4 (Oct–Dec) | 1–30 January |
These same operations also appear on your quarterly modelo 303 VAT return, in the informational boxes for operations out of scope under the place-of-supply rules. We cover the return itself in the step-by-step modelo 303 guide.
Selling to German consumers: OSS and the EUR 10,000 threshold
Everything above is B2B. If instead you sell to final consumers in Germany — intra-community distance sales of goods, or telecommunications, broadcasting and electronically supplied (digital) services — the regime changes and the One-Stop Shop (OSS) comes into play, in force since 1 July 2021.
Here a common EUR 10,000 threshold (VAT excluded) governs the total of your B2C sales across the entire EU:
- Below EUR 10,000, you tax at origin: you charge Spanish VAT on the invoice to the consumer.
- Above it, you tax at destination: you charge German VAT and declare it through the OSS, filing a single return in your member state of identification (Spain) instead of registering in each country. You can opt to tax at destination even without crossing the threshold.
This is the most common source of confusion: the EUR 10,000 threshold does not exist for invoices to businesses. In B2B the mechanism is reverse charge plus modelo 349, with no threshold, from the first euro. If your case is digital services to EU consumers, we go deep on it in the quarterly VAT guide for EU-facing freelancers.
This article covers the supply of services. If what you send to Germany is goods in a B2B operation, the treatment differs: it is generally an exempt intra-community supply with its own requirements around proof of transport and the acquirer’s VAT number in VIES (art. 25 of Law 37/1992). Check that specific case with your adviser before you issue.
Common mistakes
- Charging Spanish VAT “just to be safe.” If the operation is B2B and located at destination, adding VAT is wrong: it distorts the invoice and forces a correction later.
- Not validating the VAT number in VIES before issuing. Validity is checked at invoice time, not when you signed the contract. Keep the proof.
- Invoicing without being in the ROI. Registration via modelo 036 (box 582) comes first. Without an assigned VAT number, the reverse charge does not apply.
- Confusing B2B with OSS. The EUR 10,000 threshold is exclusive to sales to final consumers. In B2B there is no threshold.
- Withholding IRPF from a foreign client. A payer not established in Spain is not required to apply Spanish IRPF withholding; you invoice the full amount.
- Forgetting the 349. It is informational and pays nothing, but failing to file it — or filing late — is penalised. If a quarter has no intra-community operations, you do not file it for that quarter.
EU invoicing, without the tedious part
The manual flow — the correct legal note, the 303 boxes, the export to the 349, the exchange rate if you get paid in another currency — is exactly where errors creep in. Frihet detects your intra-community operations from your own invoices (a client with an EU VAT number, a VAT-free rate), builds a modelo 349 preview broken down by counterparty and operation code, and reuses those amounts in the 303 calculation so you do not add them twice by hand.
To be clear about scope: the 349 in Frihet is preview and calculation, not filing. The final submission is always yours, in the tax authority’s electronic office with your certificate. Frihet calculates and prepares the form from your invoices and expenses; you review and file.
Invoicing clients across the EU?
Frihet identifies your intra-community operations, prepares the 349 and reflects them on the 303. No adding by hand, no hunting for the VAT number on every invoice.
Executive summary (in force 2026)
- Place of supply: B2B service to a German company → located in Germany (art. 69.Uno.1º LIVA). No Spanish VAT.
- Invoice: no VAT, with the reverse-charge note «inversión del sujeto pasivo» (art. 6.1.m RD 1619/2012) and both parties’ VAT numbers (ES and DE).
- Prerequisites: ROI registration via modelo 036 (box 582) and a valid VAT number in VIES on both sides.
- Modelo 349: report the operation. Quarterly, or monthly if you exceed EUR 50,000 (VAT excl.) in the quarter or the four previous ones.
- OSS: B2C only. The EUR 10,000 (VAT excl.) threshold: below it, VAT at origin; above it, VAT at destination through the one-stop shop.
The first invoice to Germany takes a little preparation. After that, it is routine.
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FAQ
Do I charge VAT on an invoice to a German company?
No. Under the general place-of-supply rule for B2B services (art. 69.Uno.1º of Law 37/1992), the service is located where the client is established — Germany — so you do not charge Spanish VAT. You issue the invoice VAT-free and your client self-assesses the German Umsatzsteuer under the reverse-charge mechanism.
What note has to appear on the invoice?
The mandatory "reverse charge" mention — «inversión del sujeto pasivo» in Spanish (art. 6.1.m of the invoicing regulation, RD 1619/2012) — plus your Spanish VAT number (ES prefix) and the client's German VAT number (DE prefix). That note tells the recipient it is their job to account for the VAT in their country.
Do I need OSS to invoice a client in Germany?
Only if you sell to consumers (B2C): distance sales of goods or digital services to final consumers. Then the common EUR 10,000 (VAT excluded) threshold and the OSS regime apply. If your client is a business (B2B), the mechanism is reverse charge plus modelo 349, with no threshold, from the first euro.
Which form do I report the operation on?
Modelo 349, the recapitulative statement of intra-community operations (approved by Order EHA/769/2010). It is informational — it does not trigger a payment. It is filed monthly unless you stay under EUR 50,000 (VAT excluded) in the quarter and the four previous ones, in which case you file quarterly.
How long does ROI registration take?
You apply with modelo 036, ticking box 582 and stating the expected date of your first operation in box 584. The tax authority has up to 3 months to decide; if it does not respond in time, the request can be treated as denied by administrative silence. Start the process well before your first invoice.
Do I withhold IRPF from a German client?
No. The duty to withhold and remit IRPF (Spanish income-tax withholding) falls on payers established in Spain; a German business client not established in Spain does not apply Spanish IRPF withholding. You invoice the full amount. Confirm with your adviser if your case has particularities.
