How to invoice an Italian client from Spain (2026)

If you are about to bill a service to an Italian company from Spain, the short answer is: you issue the invoice with no Spanish VAT and your client accounts for the Italian VAT itself. The reason is that a service supplied to a business or professional established in another member state is located at destination — Italy — under the general rule of article 69.Uno.1º of Law 37/1992, so it is not subject to Spanish VAT. That mechanism is called reverse charge («inversión del sujeto pasivo» in Spanish). To make it valid, though, there are three prerequisites that are not optional: register in the ROI, validate your client in VIES, and report the operation on modelo 349. This guide walks through all three, in order.

The rule that changes everything: the service is located in Italy

Intra-community VAT works on one principle: in services supplied between businesses (B2B), the tax is paid in the client’s country, not the supplier’s. When a freelancer or company in Spain supplies a service to an Italian business, that service is deemed to take place in Italy 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 and art. 84 for the taxable person). In practice:

• You do not charge VAT on the invoice.
• Your Italian client self-assesses the VAT in Italy, applying its own rules and rate, through the reverse charge.
• You keep the right to deduct the input VAT you incurred to provide that service, exactly as if the operation had taken place in Spain.

This applies to services (consulting, design, development, marketing, recorded training, and so on). Supplies of goods have their own rules, but the administrative circuit — ROI, VIES and the 349 — is the same. For the full mechanics on the Spanish side, we cover it in the guide to modelo 349, the ROI and cross-border invoicing.

Before the first invoice: ROI and VIES

Here is the most expensive mistake made by people just starting out: issuing the VAT-free invoice before the paperwork is in order. If you do it without being in the ROI or without validating the client, the operation does not meet the out-of-scope requirements and the tax authority can demand the VAT you did not charge, plus surcharges and interest.

1. Register in the ROI (Register of Intra-Community Operators). You apply through the census declaration, modelo 036, ticking box 582 (registration request) and stating the expected date of your first operation in box 584. With registration, the tax authority assigns you a VAT number that prepends the ES prefix to your tax ID and adds you to the VIES census. Mind the timing: the decision takes up to 3 months and, if it passes with no reply, it is treated as denied. Apply with margin.

2. Validate the client in VIES. Before you issue, check in VIES that your Italian client’s VAT number (IT prefix) is valid and active. This is a legal condition, not a recommendation: if the client does not give you a valid VAT number, you cannot treat the operation as an intra-community, out-of-scope supply, and you would have to charge Spanish VAT. Keep the proof of each check with its date; it is your evidence in an inspection.

How to build the invoice to Italy

An invoice to your Italian client looks like a Spanish one, with two key differences: no VAT line, and a mandatory legal note.

Field	Domestic invoice	Invoice to an Italian 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»

It must also include:

• Your VAT number (ES + your tax ID) and the Italian VAT number of the client (IT + their number).
• The taxable base, with no VAT amount.
• The literal note «inversión del sujeto pasivo», required by art. 6.1.m of RD 1619/2012 (the invoicing regulation). Keep it in Spanish so it maps to the Spanish legal reference; you can add an English gloss (“reverse charge”) beside it. You may also add 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, not a non-subject service.

Worked example

A freelance designer in Valencia bills a brand-identity project to an agency in Milan for EUR 3,500. She is already registered in the ROI and has validated the agency’s Italian VAT number in VIES. Her invoice:

Item	Amount
Taxable base (brand design)	EUR 3,500.00
Spanish VAT (21%)	— not charged
Invoice total	EUR 3,500.00
Mandatory note	«Inversión del sujeto pasivo» (art. 6.1.m RD 1619/2012)

The Milan agency receives the invoice for EUR 3,500, with no Spanish VAT, and self-assesses the Italian VAT in its own return. The designer collects the full EUR 3,500 free of VAT — but that income still forms part of her base for income tax (IRPF), and for corporate tax if the issuer is a company: a VAT-free invoice does not mean the income is exempt. In practice, an invoice to an Italian client also carries no IRPF withholding, because a non-resident client does not act as a Spanish IRPF withholder.

Modelo 349: when and how often

Every service supplied to a business client in another member state is reported on modelo 349, the recapitulative statement of intra-community operations (approved by Order EHA/769/2010, of 18 March). It is an informational return: it triggers no payment, it simply cross-checks data between EU tax administrations.

Frequency depends on a threshold: EUR 50,000 (VAT excluded) in intra-community operations. Below it, quarterly filing; once you exceed that amount, you switch to monthly. The deadlines:

Period	Filing deadline
Monthly (general rule)	The first 20 calendar days of the following month
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 VAT return, these supplies also appear in the informational box for intra-community supplies: they do not change the amount due, but they must reconcile with what you reported on the 349. If you split your work between Spain and the EU, it helps to review how it all fits together in the quarterly VAT guide for EU-facing freelancers and the step-by-step modelo 303 guide.

B2B vs B2C: when the OSS appears

Everything above assumes your Italian client is a business or professional with a VAT number. If you invoice a private individual in Italy (B2C), the circuit is different: there is no reverse charge.

For intra-community distance sales of goods and for digital services (telecommunications, broadcasting and electronically supplied services), a single EUR 10,000 threshold (VAT excluded) applies, computed across the whole EU. Below it, you tax in Spain with Spanish VAT; above it, you tax in the country of consumption — Italy — and can declare it through the One-Stop Shop (OSS, Union scheme), a single registration that saves you from registering country by country. The OSS has been operational in Spain since 1 July 2021 (Royal Decree-law 7/2021 and Royal Decree 424/2021).

	B2B (Italian company)	B2C (Italian consumer)
VAT on the invoice?	No (reverse charge)	Depends on the threshold
Relevant threshold	EUR 50,000 → 349 frequency	EUR 10,000 → taxation at destination
Who accounts for the VAT	The client, in Italy	You, in Italy (via OSS) or in Spain
Return	Modelo 349	OSS (modelo 369) once you cross the threshold

If your activity includes clients outside the EU, the treatment changes again: we cover it in the guide to invoicing US clients from Spain.

An important warning if you invoice from the Canary Islands

This circuit — ROI, VAT-free invoice, modelo 349 — is designed for businesses established in mainland Spain or the Balearic Islands, which is the VAT territory. The Canary Islands, Ceuta and Melilla are outside it. The Canary Islands apply IGIC and, for EU VAT purposes, the archipelago is treated as third territory, so the intra-community VAT rules do not work the same way as on the mainland.

If you issue from the Canary Islands, do not take this guide’s instructions at face value: an operation with Italy may follow the logic of an operation with a third country rather than an intra-community one. It is a critical point and worth confirming with your adviser before you invoice.

Common mistakes when invoicing Italy

• Issuing the VAT-free invoice before being registered in the ROI.
• Not validating the Italian VAT number in VIES — or doing it but not keeping the dated proof.
• Forgetting the literal «inversión del sujeto pasivo» note on the invoice.
• Charging Spanish VAT “just to be safe”: if the operation is intra-community and out of scope, you must not add it.
• Not filing modelo 349, assuming the 303 is enough because there is no amount to pay.
• Confusing the EUR 50,000 threshold (349 frequency, B2B) with the EUR 10,000 one (B2C, taxation at destination).
• Treating an Italian private individual as if they were a company and applying reverse charge.
• Assuming that from the Canary Islands the circuit is identical to the mainland.

How Frihet automates it

Invoicing Italy adds steps that are easy to forget when you run the process 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 is ready when it is time to file, alongside the correct entry on your modelo 303. The engine handles the VAT, IGIC and IRPF treatment your activity needs, including VeriFactu operations, 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 carry out with the tax authority. What it does prevent is an invoice going out with a formal error, or an EU sale left un-reconciled. The rest — who accounts for the tax, with which note, on which form — stops depending on your memory.

Invoicing a client in Italy is not complicated: it becomes routine once you have the ROI, validate the client, and know which note to add. The first invoice takes a little more effort; from the second onward, it is a two-minute task.