How to invoice a Dutch client from Spain (2026)
A Spain-based freelancer's guide to billing a Netherlands company: no Spanish VAT, the reverse-charge note, VIES validation, ROI registration and modelo 349.
TL;DR: A B2B service billed by a Spain-based freelancer or company to a Netherlands business is located where the client is (art. 69.Uno of Law 37/1992): you issue the invoice with no Spanish VAT and the "reverse charge" note, and the Dutch client self-assesses the BTW in the Netherlands. You need both parties' VAT numbers valid in VIES, ROI registration via modelo 036, and to report the operation on modelo 349. OSS and its EUR 10,000 threshold do not apply here — they are for sales to final consumers (B2C) only.
Key takeaways
- Under the general place-of-supply rule (art. 69.Uno of Law 37/1992), a B2B service billed to a Netherlands company is located in the Netherlands — 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 BTW (Dutch VAT) at destination.
- Before you invoice, register in the ROI via modelo 036 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: monthly by default, or quarterly if you stay under EUR 50,000 (VAT excluded) this quarter and the four previous ones (filed 1–20 April, July and October; 1–30 January for Q4).
- OSS and its EUR 10,000 (VAT excluded) threshold are exclusive to sales to final consumers (B2C); in B2B the mechanism is reverse charge plus modelo 349, with no threshold, from the first euro.
Contents
You have signed a Dutch 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 the Netherlands 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 of Law 37/1992), a B2B service is located where the client is established — the Netherlands — so you do not charge VAT: the client self-assesses the BTW (Dutch 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 play no part here — they are reserved for sales to final consumers.
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 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 Netherlands company, the operation is located in the Netherlands 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. It mirrors the case the Spanish tax authority itself describes — a service by a non-established professional to a Spanish company, where the Spanish company is the taxable person by reversal (art. 84.Uno.2º.a of Law 37/1992). Here the roles are flipped: you, the Spanish supplier, invoice without VAT, and the Netherlands company self-assesses the BTW in the Netherlands at whatever rate applies there.
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. 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), ticking the box that requests inclusion in the register. Being assigned the VAT number means being added to the VIES census. Your VAT number is
ES+ your tax ID, and it must appear on your invoices. - Validate the client’s VAT number in VIES. Before you invoice, check that your client’s Dutch VAT number (
NLprefix) is valid in the VIES census (the VAT Information Exchange System, run by the European Commission). If the client does not have a valid VAT number, you cannot treat the operation as a B2B intra-community supply.
The full registration process and the mechanics of the register are covered in the modelo 349 and ROI registration guide.
How to build the invoice, field by field
An invoice to the Netherlands is almost identical to a domestic one, with three differences:
| Field | Domestic invoice | Invoice to a Netherlands 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 Dutch VAT number, each with its country prefix.
Worked example
A Spanish consultant bills 20 hours of advisory work to a company in Amsterdam at EUR 150/hour:
| Item | Amount |
|---|---|
| Strategy consulting (20 h × EUR 150/h) | EUR 3,000.00 |
| Taxable base | EUR 3,000.00 |
| VAT (out of scope — reverse charge) | EUR 0.00 |
| Total to collect | EUR 3,000.00 |
Supplier VAT no.: ES12345678A · Client VAT no.: NL123456789B01 Out of scope by place of supply (art. 69 Law 37/1992). Reverse charge.
The Dutch client receives EUR 3,000 in full and accounts for the BTW 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 Netherlands company falls under article 70, the location can change and the destination rule does not automatically apply. When in doubt, check before you issue: the VAT treatment on the invoice, and the box you use, depend 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. 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.
On the 349, supplies of services are identified with the services operation code set out in the form’s instructions (the “S” code, under the standard 349 coding). Frequency depends on volume:
| Situation | Frequency |
|---|---|
| Intra-community operations > 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 at the end of any month within a quarter, you switch to monthly filing. The deadlines in force in 2026:
| Period | Filing deadline |
|---|---|
| Monthly¹ | 1–20 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 |
¹ With two official exceptions: July can be filed until 20 September, and December from 1 to 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 of articles 69 and 70. The exact box can change between years, so verify it on the current period’s form before filing. We cover the return itself in the step-by-step modelo 303 guide.
Why OSS does not apply to this invoice
This is the most common source of confusion. The OSS (One-Stop Shop) and its well-known EUR 10,000 threshold have existed since 1 July 2021, but they are a B2C regime: they only cover intra-community distance sales of goods and telecommunications, broadcasting and electronically supplied (digital) services provided to final consumers in the EU.
- Below EUR 10,000 of those B2C sales to the EU as a whole, you tax at origin (Spanish VAT).
- Above it, you tax at destination and declare through the OSS (self-assessment via modelo 369).
None of this applies to an invoice for services to a Netherlands company. 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, that is where OSS does come into play, and we go deep on it in the quarterly VAT guide for EU-facing freelancers.
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.
- Treating the Netherlands as an OSS case. The EUR 10,000 threshold is B2C. 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.
- Thinking that “invoicing the EU” changes your business activity code. Your IAE code depends on the activity you carry out, not on your client’s country. There is no specific code “for invoicing Europe.”
- 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 exchange rate if you get paid in another currency, the correct legal note, the 303 boxes, the export to the 349 — 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 Netherlands company → located in the Netherlands (art. 69.Uno 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 NL).
- Prerequisites: ROI registration via modelo 036 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: does not apply. The EUR 10,000 threshold is B2C only.
The first invoice to the Netherlands takes a little preparation. After that, it is routine.
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FAQ
Do I charge VAT on an invoice to a Netherlands company?
No. Under the general place-of-supply rule for B2B services (art. 69.Uno of Law 37/1992), the service is located where the client is established — the Netherlands — so you do not charge Spanish VAT. You issue the invoice VAT-free and your client self-assesses the Dutch BTW 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 Dutch VAT number (NL 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 the Netherlands?
No, if your client is a business (B2B). The OSS one-stop shop and its EUR 10,000 threshold are reserved for distance sales and digital services to final consumers (B2C). For 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. 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.
Do I withhold IRPF from a Dutch client?
No. The duty to withhold and remit IRPF (Spanish income-tax withholding) falls on payers established in Spain; a Netherlands 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.
What if the client has no valid VAT number in VIES?
Then you cannot treat the operation as a B2B intra-community supply. Without a valid, VIES-verifiable Dutch VAT number, the reverse charge does not apply; you would need to review the nature of the operation (for example, whether it is in fact a sale to a final consumer). Always check before you issue.
