How to invoice a client in Mexico from Spain (2026)

If you are a freelancer or a company in Spain billing a service to a client in Mexico, the base rule is simple: you issue the invoice with no Spanish VAT. Mexico is a third country (outside the European Union), so a service between businesses is located where the client is established, under the general rule of art. 69.Uno.1º of Law 37/1992; since that place is outside the scope of Spanish VAT, the operation is not subject to Spanish VAT and you invoice with no VAT line under the place-of-supply rules. So far, this is like any client outside the EU. What makes Mexico distinctive is the second layer: the Spain-Mexico double-taxation treaty, which decides whether the Mexican tax authority can withhold part of your payment and by how much. With the right characterisation of the payment and the right certificate, that withholding is usually zero. Let’s walk through the whole circuit.

Why the invoice to Mexico carries no Spanish VAT

It starts with the place-of-supply rule. For services between businesses (B2B), VAT is paid — where it applies at all — in the country where the client is, not the country of the supplier. Article 69.Uno.1º of Law 37/1992 sets it out: a service supplied by a Spanish business to a business established outside the scope of Spanish VAT is deemed supplied at the client’s place of business. If that place is in Mexico, the operation is located there and is not subject to Spanish VAT.

The Spanish tax agency confirms this treatment for services supplied abroad: the operation is not subject to Spanish VAT. In practice, the invoice goes out not subject, with no VAT line.

There is an upside few people highlight: even though you charge zero, you keep your full right to deduct the input VAT on your related expenses, exactly as if the operation had taken place in Spain. Because you charge zero and deduct everything, your modelo 303 will often come out as a credit or a refund. The general circuit for clients outside the EU is covered in our guide to exporting services outside the EU.

It is not intra-EU: no modelo 349, no VIES, no reverse charge

The number-one mistake when invoicing Mexico is treating it like a client in Germany or France. It isn’t. Mexico is a third country, and the whole intra-EU machinery does not apply:

• No modelo 349. The recapitulative return only covers operations with businesses in other EU member states. An invoice to Mexico falls outside it. If you want to know when that return does apply, see our guide to modelo 349 and cross-border invoicing.
• No VAT number or VIES. The intra-EU VAT number and the VIES register are only required to trade with businesses in other member states. You don’t need one for a Mexican client, nor do you verify your client in VIES.
• No EU reverse charge. The “reverse charge” of art. 84 of Law 37/1992 belongs to the common European system; it plays no part with Mexico. Any indirect-tax obligations in Mexico, if there are any, follow Mexican rules.

Here Mexico behaves like any other non-EU destination. If you also invoice the United States, the VAT treatment is identical and is broken down in our guide to invoicing a US client.

What the invoice must say

An invoice to a Mexican client is almost identical to a domestic one, but with two differences you cannot skip: it carries no VAT line, and it must include the not-subject-to-VAT note.

Field	Domestic invoice	Invoice to a Mexican business
VAT rate	21% / 10% / 4%	No VAT (not subject, place of supply)
VAT amount	Calculated	0.00
Currency	Euros	Euros or Mexican pesos (your choice)
Legal note	Not required	Reference to the not-subject rule

The mandatory content is set by article 6 of RD 1619/2012 (the invoicing regulation): number and, where applicable, series; issue date; name and tax ID of both you and the client; the addresses of both; a description of the operation with its taxable base; and the transaction date if it differs from the issue date. To that you add, as recommended documentation practice (the obligation to invoice this not-subject operation derives from art. 2.3 of the same regulation), the note that the operation is not subject to VAT — a non-subjection by place of supply, not an exemption, which is a distinct category with its own letter in art. 6.1. A common, valid wording:

Operation not subject to Spanish VAT under the place-of-supply rules — art. 69 of Law 37/1992.

You can find the field-by-field detail of a correct invoice in the freelancer invoicing guide for Spain. One Mexican-side nuance: for your client to deduct the expense, Mexican rules will usually require him to hold a CFDI (Comprobante Fiscal Digital por Internet). That is his obligation under Mexican law, not yours under Spanish law: you issue your invoice under RD 1619/2012 and coordinate with him on how he covers the CFDI part.

Invoicing in Mexican pesos: currency and exchange rate

You can issue the invoice directly in Mexican pesos (MXN). Article 12 of RD 1619/2012 lets you express the amounts in any currency; the only condition is that any VAT charged also be shown in euros. Since your invoice to Mexico carries no VAT, there is nothing to convert on that front.

That said, even if you charge in pesos, the taxable base must be converted to euros — at the transaction-date exchange rate — for three things: your modelo 303, your income-tax return and your books. Good practice is to record the euro equivalent and the rate used on the invoice itself or in your records. If you invoice regularly in several currencies, the treatment of exchange differences is covered in our guide to invoicing in multiple currencies from Spain.

Source withholding and the Spain-Mexico treaty

This is the real difference from other destinations. Mexico, like many countries, applies source withholding on payments to foreign suppliers, and its domestic rates are notably high. What stops it from over-withholding — and from that amount stacking on top of the tax you already pay in Spain — is the Spain-Mexico double-taxation treaty (ratification instrument published as BOE-A-1994-23743, signed on 24 July 1992), amended by the Protocol of 17 December 2015 (BOE-A-2017-7905). The treaty divides up the right to tax each type of income and sets source-withholding caps:

Type of income	Treaty article	Maximum withholding in Mexico
Business profits	Art. 7	0% (unless there is a permanent establishment in Mexico)
Independent personal services	Art. 14	0% (unless there is a fixed base in Mexico, or presence > 183 days)
Royalties	Art. 12 of the treaty	10% of the gross amount
Technical assistance	Art. 7 / 14 (after Protocol)	Treated as a service, not as a royalty
Dividends	Art. 10	10% general; 0% if you hold ≥ 10% of capital or are a pension fund
Interest	Art. 11	4.9% (banks and listed bonds); 10% otherwise; 0% pension funds

For a freelancer or company supplying a professional service, the first two rows are the key ones: if your invoice is a genuine service (business profits under art. 7 or an independent personal service under art. 14, which also requires staying under 183 days of presence in Mexico), that income is taxed only in Spain unless you have a permanent establishment or fixed base in Mexico, or exceed that presence threshold. In that case Mexico should not withhold anything.

The nuance to watch is how the payment is characterised. If what you grant is the use of software, a patent, know-how or other industrial or intellectual property rights, the payment may be characterised as a royalty (art. 12 of the treaty), and there Mexico can withhold, capped at 10%. A relevant point from the 2015 Protocol: technical assistance stopped being treated as a royalty and moved to the services route (art. 7/14), which in practice usually removes the withholding on that item when you provide the right documentation.

The certificate of tax residence: your key to the treaty

The treaty does not apply itself — you have to activate it. For the Mexican payer to avoid withholding (or to withhold at the reduced treaty rate instead of the Mexican domestic rate), you must give him a certificate of tax residence for treaty purposes issued by the AEAT. It is the document proving you are a Spanish tax resident and therefore entitled to the treaty’s benefits.

Without that certificate, the Mexican client will typically apply his higher domestic withholding to be safe. Recovering that difference later is cumbersome, so it pays to have it ready before you issue your first invoice. You request it from the AEAT (usually the specific “for treaty purposes” version, not the generic one); it has a limited validity and is renewed periodically. Whenever you can, also document that your client is a business or professional: that is what underpins the B2B treatment of the whole operation.

A worked example

A Spanish consultancy supplies a strategy service to a company in Mexico City for MXN 100,000. For illustration, assume a hypothetical rate of 19 MXN per euro (always use the real official rate of your transaction date):

Item	Amount
Consulting services	MXN 100,000.00
VAT (not subject, place of supply)	0.00
Total to collect	MXN 100,000.00
Euro equivalent of the base (example, €1 = 19 MXN)	EUR 5,263.16

Operation not subject to Spanish VAT — art. 69 of Law 37/1992.

Because this is a genuine service (art. 7 of the treaty) and you have provided your certificate of tax residence, Mexico does not withhold: you collect the full MXN 100,000. You charge no VAT, but you record EUR 5,263.16 as the base (at your date’s real rate) for modelo 303 and income tax. That euro figure is what you carry into every return: on modelo 303 it is reported as a not-subject operation, on place-of-supply grounds, with a right to deduct. Where it goes exactly is covered in the step-by-step modelo 303 guide.

If instead that payment were a royalty (art. 12 of the treaty), Mexico could withhold up to 10%: MXN 10,000, and you would collect MXN 90,000. That withholding is not lost: you recover it in Spain through the double-taxation deduction.

The income is taxed in Spain: income tax and treaty relief

An invoice without VAT does not mean tax-free income. The income is still taxed. It enters your personal income tax (if you are a freelancer) or your corporate income tax (if you invoice through a company), both of which tax your worldwide income: quarterly payments on account and the annual return.

If in some case Mexico validly withholds under the treaty — say that 10% on a royalty — Spain relieves the double taxation through the foreign double-taxation deduction (art. 80 of the income tax law / art. 31 of the corporate tax law), within the limit the treaty sets. In practice: always keep the Mexican withholding certificate, because that is what lets you offset it on your Spanish return.

Common mistakes

• Treating Mexico like an EU client. No reverse charge, no VIES, no modelo 349: it is a third country. Putting a Mexican invoice on modelo 349 is a classic error.
• Charging Spanish VAT “just in case”. If the operation is located at destination, charging VAT distorts the invoice and forces you to reissue it.
• Not requesting the certificate of tax residence before invoicing. That is what activates the treaty; without it, your Mexican client applies his higher domestic withholding, and recovering the difference is slow.
• Confusing a service with a royalty. Granting the use of software or intellectual property may be characterised as a royalty (up to 10% withholding). Technical assistance, after the 2015 Protocol, goes through the services route: check carefully what you are actually invoicing.
• Forgetting to convert to euros. Even if you charge in pesos, the euro base (transaction-date exchange rate) is what goes to modelo 303, income tax and your books.
• Losing the Mexican withholding certificate. Without it you cannot claim the double-taxation deduction in Spain.

Invoicing Mexico, without the tedious part

The manual flow — the correct legal note, the peso invoice with its euro equivalent, the exchange rate of the date, carrying the base into modelo 303 without double-counting it, tracking the treaty withholding — is exactly where errors creep in. Frihet recognises your operations with clients outside the EU from your own invoices (non-EU client, zero-VAT rate), applies the correct not-subject note, stores the peso amount alongside its euro equivalent at the date’s exchange rate, and reuses that base to prepare the modelo 303 preview.

To be clear about scope: Frihet calculates and prepares the return from your invoices and expenses; the final filing is always yours, at the AEAT’s electronic office with your certificate. You review and file.

Executive summary (valid for 2026)

1. Place of supply: a B2B service to a Mexican company is located at destination (art. 69.Uno.1º of Law 37/1992). No Spanish VAT, but you keep the right to deduct input VAT.
2. Nothing intra-EU: no modelo 349, no VAT number/VIES, no EU reverse charge.
3. Invoice: no VAT line, with the recommended not-subject note (“Operation not subject to Spanish VAT under place-of-supply rules — art. 69 LIVA”); you may issue it in Mexican pesos (art. 12). Your client handles his CFDI.
4. Spain-Mexico treaty: services (art. 7/14) → 0% Mexican withholding with your residence certificate; royalties (art. 12 of the treaty) → capped at 10%.
5. The income is taxed in Spain: income tax or corporate income tax; if Mexico withheld, claim the foreign double-taxation deduction (art. 80 income tax law / art. 31 corporate tax law).

The first invoice to Mexico takes a little preparation — mainly the residence certificate. After that, it’s routine.