How to invoice a client in Ireland (2026)
A 2026 guide to invoicing an Irish client from Spain: no-VAT invoice, reverse charge, ROI registration, VIES, Modelo 349, the IE vs XI trap and the OSS.
TL;DR: Invoicing a B2B service to an Irish company with a valid VAT number (prefix IE) is done without Spanish VAT: the client self-assesses the tax in Ireland under the reverse charge (art. 69.Uno.1º and art. 84 of Law 37/1992). To do it you must be on the ROI (Modelo 036), verify the client in VIES and report the operation on Modelo 349 with key S. Two traps: Northern Ireland (prefix XI) only counts as EU for goods, and the €10,000 B2C threshold does not cover every service.
Key takeaways
- A B2B service to an Irish company with a valid VAT number (prefix IE) is not subject to Spanish VAT: you invoice without VAT and the client self-assesses the tax in Ireland under the reverse charge (art. 69.Uno.1º and art. 84 of Law 37/1992).
- Before you invoice, you must be registered on the ROI. You apply with Modelo 036, ticking box 582 (registration) and entering the expected date of your first operation in box 584. If AEAT does not resolve within 3 months, it counts as denied.
- The operation is reported on Modelo 349 with key S (supply of services). It is monthly, unless the amount stays below €50,000 (VAT excluded) in the reference quarter and each of the four previous ones, in which case it is quarterly.
- The Republic of Ireland uses the prefix IE (goods and services); Northern Ireland uses XI and, under the Brexit protocol, only counts as EU territory for GOODS, not services. Check the VAT-number prefix before invoicing.
- The €10,000 B2C threshold only covers distance sales of goods and digital (TBE) services. Above it, Irish VAT applies (standard 23%) via OSS (Modelo 369). A normal professional service to an Irish consumer is located in Spain and carries Spanish VAT at 21%.
Contents
You win a client in Ireland, the work is scoped, and then the invoice stalls on the VAT line. Short answer: if your client is an Irish company with a valid VAT number, that invoice goes out with no Spanish VAT. The service is deemed supplied in Ireland, and the client settles the tax there under the reverse charge. But to do it properly — and to survive a tax check — you need three things in order: registration on the ROI, verification of your client in VIES, and reporting the operation on Modelo 349. This guide covers the full 2026 flow for a Spain-based freelancer or company, plus the two variants people miss with Ireland: the difference between the Republic (prefix IE) and Northern Ireland (prefix XI), and what happens when you invoice a consumer.
The rule that decides everything: the service is located in Ireland
Intra-community VAT rests on one principle: for business-to-business (B2B) services, the tax is paid in the customer’s country, not the supplier’s. When a Spanish freelancer or company supplies a service to an Irish business, that service is deemed supplied where the customer is established — Ireland — under the general rule of art. 69.Uno.1º of Law 37/1992 (the Spanish VAT Act). The consequence: it is not subject to Spanish VAT.
That mechanism is the reverse charge (inversión del sujeto pasivo), set out in art. 84 of Law 37/1992. In practice it means three things:
- You do not charge VAT on the invoice.
- Your Irish client self-assesses the VAT in Ireland, applying its own rules and rate.
- You keep the right to deduct the input VAT you incurred to provide the service.
This applies to professional services — consulting, software development, design, marketing, recorded training, and the like. For the full mechanics, see the guide to the reverse charge.
Before the first invoice: ROI and VIES
The most expensive beginner’s mistake is issuing the VAT-free invoice before the paperwork is in order. Without the ROI, or without validating the client, you expose yourself to formal penalties and to the operation failing the conditions for non-taxation, risking AEAT claiming the VAT you never charged, plus surcharges and interest.
1. ROI registration (Register of Intra-Community Operators). You apply 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, AEAT assigns you a VAT number that prefixes ES to your NIF and lists you in the VIES system. Mind the timeline: the administration has three months, and if it passes with no answer the VAT number is treated as denied (negative silence). Apply with margin. The full process is in the guide to Modelo 349 and cross-border invoicing.
2. Client validation in VIES. Before issuing, check in VIES that your Irish client’s VAT number (prefix IE) is valid and active. This is a legal condition, not a nice-to-have: if the client does not give you a valid VAT number, you cannot treat the operation as an intra-community, non-taxable supply. Keep proof of each check with its date; it is your evidence in an audit.
How the invoice to Ireland is issued
The invoice to your Irish client looks like a domestic one, with two differences: no VAT line, and one legal mention. It must include:
- Your VAT number (ES + your NIF) and the client’s Irish VAT number (IE + their number).
- The taxable base, with no Spanish VAT.
- An express mention that the operation is subject to reverse charge (inversión del sujeto pasivo).
A worked example
A freelance developer in Valencia invoices a software project to a company in Dublin for €5,000. She is already on the ROI and has validated the client’s Irish VAT number in VIES. Her invoice:
| Item | Amount |
|---|---|
| Taxable base (software development) | €5,000.00 |
| Spanish VAT | — not charged |
| Invoice total | €5,000.00 |
| Mandatory mention | ”Reverse charge” (inversión del sujeto pasivo) |
The Dublin company receives the invoice for €5,000, with no Spanish VAT, and self-assesses Irish VAT at the rate in force there (standard 23%). The developer collects the full €5,000 free of VAT, but that income still counts toward her income tax (IRPF, or Corporate Income Tax if the issuer is a company): a VAT-free invoice does not mean tax-free income. And an invoice to an Irish client carries no Spanish IRPF withholding, because a non-resident client does not act as a withholding agent for Spanish income tax.
Modelo 349: key S, frequency and deadlines
Every supply of services to a business customer in another member state is reported on Modelo 349, the recapitulative statement of intra-community operations, with key S (supplies of services). It is an information return: it generates no payment, it only cross-references data between EU tax administrations. The obligation — set out in art. 79 of the VAT Regulation (Royal Decree 1624/1992) — reaches every business or professional with intra-community operations, regardless of VAT regime, and it is not filed for periods with no operations.
Frequency turns on one threshold: €50,000 (VAT excluded). It is monthly by default; it becomes quarterly only if the total value of supplies of goods and services to be reported does not exceed that limit in the reference quarter or in any of the four previous calendar quarters. If the threshold is crossed within a month, you return to monthly filing. The deadlines:
| Period | Filing deadline |
|---|---|
| Monthly (general rule) | First 20 calendar days of the following month |
| July | During August and the first 20 calendar days of September |
| Quarterly (general rule) | First 20 calendar days of the month after the quarter |
| December / fourth quarter | First 30 calendar days of January |
These supplies also appear in the information box of your quarterly Modelo 303: they do not change the amount due, but they must reconcile with what you reported on the 349. If you split your activity between Spain and the EU, it helps to review how it all fits together in the guide to quarterly VAT for freelancers who invoice the EU.
Ireland (IE) versus Northern Ireland (XI): the Brexit trap
This is the detail that makes Ireland a special case. Two distinct tax regimes coexist on the island:
- Republic of Ireland. A full EU member state. Its VAT number carries the prefix IE, and both services and goods follow the intra-community rules described in this guide.
- Northern Ireland. Part of the United Kingdom, but under the Brexit protocol it keeps a special status: its VAT number uses the prefix XI and only counts as EU territory for goods, not services.
The practical consequence is direct. If you sell goods to a client with an XI VAT number, the operation is an intra-community supply like any other in the EU. But if you supply a service to that same XI client, you are no longer dealing with an intra-community supply: the customer is treated as outside the EU for services, under different place-of-supply rules. Before invoicing, look at the prefix of the VAT number the client gives you: IE and XI are not interchangeable. For operations with clients outside the EU, we cover the treatment in the guide to exporting services outside the EU.
B2B versus B2C: when the OSS appears (and when it does not)
Everything above assumes your client is a business or professional with a VAT number. If you invoice a private individual in Ireland (B2C), the circuit is different: there is no reverse charge. And here is a nuance that is often over-generalized.
The One-Stop Shop (OSS) and the common €10,000 threshold (VAT excluded) do not cover every service. They apply only to distance sales of goods and to digital services — telecommunications, broadcasting and electronic services (TBE) — aggregated across all your B2C operations in the whole EU. Below the threshold you charge Spanish VAT; above it you tax in the country of consumption — Ireland — and can declare it through the One-Stop Shop (OSS, Modelo 369) without registering country by country.
The key point: a normal professional service (consulting, design, custom software, marketing) supplied to an Irish consumer does not fall under the OSS. Under the general rule for services to consumers (art. 69.Uno.2º of Law 37/1992), it is located where your seat is — Spain — and you charge Spanish VAT at 21%. Do not apply the OSS or the €10,000 threshold to these services: it is a common and costly mistake.
When Irish VAT does apply (distance sales of goods or TBE services above the threshold), these are the rates in force in Ireland from 1 January 2026:
| Irish VAT rate | Percentage |
|---|---|
| Standard | 23% |
| Reduced | 13.5% |
| Second reduced | 9% |
| Livestock | 4.8% |
| Farmers (flat-rate) | 4.5% |
The rate you apply depends on the specific product or service; the 23% standard covers most cases. If you sell products or digital services to consumers, the detail is in the guide to EU VAT on digital services and the OSS.
| B2B (Irish company) | B2C (Irish consumer) | |
|---|---|---|
| VAT on the invoice? | No (reverse charge) | Depends on the service and threshold |
| Relevant threshold | €50,000 → Modelo 349 frequency | €10,000 → only distance goods and TBE services |
| Who settles the VAT | The client, in Ireland | You (Spanish VAT, or Irish VAT via OSS if applicable) |
| Reported on | Modelo 349 (key S) | OSS (Modelo 369) if applicable and above threshold |
Common mistakes when invoicing Ireland
How Frihet automates it
Invoicing Ireland adds steps that are easy to forget when you run the operation by hand. With Frihet you issue the invoice already free of Spanish VAT and with the reverse-charge mention built in, and the operation is flagged as intra-community so the Modelo 349 data is ready when it is time to file, with the right reflection in your Modelo 303. Frihet calculates and prepares the VAT, IGIC and IRPF treatment your activity needs from your own invoices and expenses — VeriFactu operation 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 remain steps you or your adviser handle with AEAT. What it does prevent is an invoice going out malformed, or an EU sale left un-reconciled. Invoicing a client in Ireland is not complicated: it becomes routine the moment you are on the ROI, validate the client, and know which mention to add.
This guide is informational and reflects the rules in force in 2026. For cases with special rules (real estate, events) or doubts about your specific situation, confirm with AEAT’s electronic office or your adviser.
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FAQ
Do I charge VAT on an invoice to a client in Ireland?
If the client is an Irish business or professional with a valid VAT number (prefix IE), no. Under the general place-of-supply rule for B2B services (art. 69.Uno.1º of Law 37/1992), the service is deemed supplied in Ireland and is not subject to Spanish VAT: you invoice without VAT and the client self-assesses the tax in Ireland under the reverse charge. If the client is a consumer, the answer depends on the type of service.
Do I need to be on the ROI to invoice Ireland without VAT?
Yes. To operate VAT-free with EU businesses you must be identified on the Register of Intra-Community Operators (ROI), which lists you in VIES and assigns you a VAT number with the prefix ES. You apply with Modelo 036, ticking box 582 and stating the expected date of your first operation in box 584.
What is the difference between Ireland (IE) and Northern Ireland (XI)?
The Republic of Ireland is a full EU member state: its VAT number uses the prefix IE and both goods and services follow the intra-community rules. Northern Ireland is part of the UK, but under the Brexit protocol keeps a special status: its VAT number uses the prefix XI and only counts as EU territory for GOODS, not services. This is decisive — a service to an XI client does not follow the same circuit as one to an IE client.
How do I report the invoice to Spain?
An intra-community supply of services is reported on Modelo 349, the recapitulative statement of intra-community operations, with key S. It is an information return — it generates no payment. It is monthly, unless you stay below €50,000 (VAT excluded) in the reference quarter and each of the four previous ones, in which case it is quarterly.
What if my Irish client is a consumer?
It depends on the service. For distance sales of goods and digital services (telecommunications, broadcasting and electronic services) the common €10,000 annual threshold applies: below it you charge Spanish VAT; above it, Irish VAT (standard 23%), declared through the One-Stop Shop (OSS, Modelo 369). But a normal professional service to an Irish consumer is located in Spain and carries Spanish VAT at 21%.
How do I check that the Irish VAT number is valid?
By checking your client's number (prefix IE) in the European Commission's VIES system before issuing the invoice. A valid VIES number at the moment of invoicing is the evidence AEAT expects for treating the operation as intra-community and VAT-free. Keep the proof of the check with its date.
