How to invoice a Swiss client from Spain (2026)

If you are a freelancer or a company in Spain billing a service to a client in Switzerland, the rule is straightforward: you issue the invoice with no Spanish VAT. Switzerland 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. But there is a nuance almost nobody explains that actually saves you money: this is not an exemption or a “0% rate” — it is a non-subjection by place-of-supply, and that is precisely why you keep the right to deduct your input VAT. On top of that, it is not an intra-EU operation: no modelo 349, no EU VAT number, no VIES registration, and you can charge in Swiss francs. Let’s walk through the whole circuit.

Why the invoice to Switzerland 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 Switzerland, the operation is located there and is not subject to Spanish VAT. In practice, the invoice goes out with no VAT amount.

One distinction up front, because it trips a lot of people up. This is not the “exempt export” that applies to goods physically leaving the EU (that is a different figure, art. 21 of Law 37/1992, and it is only for goods). With services we are not talking about exporting merchandise but about where the service is deemed supplied. The fact that the correct label is “not subject” rather than “exempt” is not a harmless technicality — as you will see next, it changes your right to deduct. The general circuit for clients outside the EU is covered in our guide to exporting services outside the EU.

Not subject, not exempt: why the difference saves you money

Here is the point that separates a good invoice from one that costs you money. Many “no VAT” operations are limited exemptions: you do not charge VAT, but you also cannot deduct the input VAT on your expenses. The invoice to Switzerland does not work that way.

Because it is an operation carried out outside the scope of Spanish VAT that would give rise to a right to deduct if it had been carried out inside Spain, article 94.Uno.2º of Law 37/1992 keeps your full right to deduct the input VAT on the expenses tied to that activity. You charge zero and deduct everything: that is why this setup is informally called “exporting services”. In practice, if a good share of your billing goes to Switzerland (or other third countries), your modelo 303 VAT return often comes out as a credit or a refund, precisely because you keep deducting your input VAT while charging none on these sales.

Switzerland is a third country: no modelo 349, no VIES, no ROI

This is the number-one mistake when billing Switzerland: treating the operation as if the client were in Germany or France. It is not. Switzerland is a third country, and the whole intra-EU scaffolding does not apply:

• No modelo 349. The recapitulative return only covers intra-EU operations: an intra-EU supply of services requires the recipient to be a business in another member state (arts. 78 and 79 of RD 1624/1992). Switzerland falls outside it. If you want to see when that form does apply, we cover it in the modelo 349 and ROI guide.
• You do not need an EU 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 do not need either for a Swiss client, nor do you have to verify your client in VIES.
• No ROI registration. The Register of Intra-EU Operators is, again, an EU matter. Your ordinary business registration in the census via modelo 036 is enough.

On the VAT return, this sale is reported as a non-subject operation by place-of-supply with the right to deduct: it does not add to your output VAT, but it records the operation and preserves your right to deduct. The exact box on the form is worth confirming in the return’s instructions on the AEAT electronic office before you file.

What if your Swiss client is a private individual (B2C)?

Everything above assumes you are billing a business or professional. What if your client is a private individual resident in Switzerland? For many professional services the result is the same — no Spanish VAT — but through a different route: article 69.Dos of Law 37/1992. When the recipient is not a business and is established outside the Community, certain services are also deemed not supplied in Spain. The list (letters a to l of art. 69.Dos) includes, among others:

• Assignments of copyright, patents, trademarks and other intellectual or industrial property.
• Advertising.
• Consulting, auditing, engineering, legal, advisory and accounting or tax expert services.
• Data processing and the supply of information.
• Translation, proofreading and interpreting.

Electronically supplied services, telecommunications, and broadcasting and television are not on this list: since the 2015 reform (Ley 28/2014) they are governed by art. 70.Uno.4º and 70.Uno.8º of Law 37/1992, which locate them at the consumer’s residence. For a Swiss individual, the practical result is the same: no Spanish VAT.

If your service to a Swiss individual fits one of these letters, you invoice with no Spanish VAT. If it does not fit (for example, some services performed and consumed in Spain), you would need to check the general rule and the special rules before concluding.

What the invoice must say

The fact that the operation is not subject to VAT does not exempt you from invoicing: article 2 of RD 1619/2012 (the invoicing regulation) extends the duty to issue an invoice to non-subject operations as well. The invoice to a Swiss client is almost identical to a domestic one, with two differences you cannot skip: it carries no VAT amount and it is worth stating why.

Field	Domestic invoice	Invoice to a Swiss company
VAT rate	21% / 10% / 4%	No VAT (not subject, place-of-supply)
VAT amount	Calculated	Not stated
Reverse-charge note	Not applicable	Not applicable (only if the recipient is liable for Spanish VAT)
Currency	Euros	Euros or Swiss francs (your choice)

The general mandatory content is set by article 6 of RD 1619/2012: number and, where applicable, series; issue date; your and your client’s name and tax ID; both addresses; a description of the operation with its taxable base; and the transaction date if it differs from the issue date. Two important points for the Swiss case:

• No VAT amount is stated, because none is charged.
• No “reverse charge” note applies: that note (art. 6.1.m) only applies when the recipient is liable for Spanish VAT, and a Swiss client, from a third country, is not. Likewise, the mandatory reference in art. 6.1.j is reserved for exempt operations, not non-subject ones.

Although not mandatory, it is good practice to add a line explaining why the invoice carries no VAT, so your client does not think you forgot it. A clear wording:

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

The field-by-field breakdown of a correct invoice is in the invoicing guide for freelancers in Spain.

Invoicing in Swiss francs (CHF): currency and exchange rate

You can issue the invoice directly in Swiss francs (CHF). Article 6 of RD 1619/2012, which lists the invoice content, does not require it to be issued in euros, so charging in your client’s currency is perfectly valid.

That said, even if you invoice in francs, the base must be converted to euros for three things: modelo 303, your income-tax return and your bookkeeping. The conversion criterion is set by article 79.Once of Law 37/1992: consideration set in a currency other than the euro is converted using the selling exchange rate set by the Bank of Spain in force at the time of accrual. Good practice is to record on the invoice (or in its ledger) the euro equivalent and the exchange rate applied, with its date. If you invoice often in several currencies, we cover exchange-rate differences in the guide to invoicing in multiple currencies from Spain.

A worked example

A Spanish consultancy supplies a strategy service to a company in Zurich for CHF 6,000. As an illustration, suppose the exchange rate on the accrual date were 0.96 CHF per euro (always use the actual official rate for your date):

Item	Amount
Consulting services	CHF 6,000.00
VAT (not subject, place-of-supply)	Not stated
Total to collect	CHF 6,000.00
Euro equivalent of the base (example, 0.96)	EUR 6,250.00

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

The Swiss client pays CHF 6,000 in full. You do not remit any VAT on this operation, but you record EUR 6,250 of base (at your date’s actual rate) for the 303, your income tax and your books. That euro figure is what you carry into every return. Where exactly it goes is covered in the step-by-step modelo 303 guide.

Income tax and withholding: the income is still taxed

The invoice carrying no VAT does not mean the income is tax-free. The income is still taxed. Because the payer is a Swiss company not required to withhold in Spain, your invoice carries no income-tax withholding: a Swiss client operating outside Spain and with no permanent establishment here is not among the parties “required to withhold or pay on account” under article 76 of RD 439/2007. You collect the gross amount, but that income enters your Spanish income tax like any other business income — quarterly payments on account and the annual return — with the base already converted to euros.

A word on scope: Swiss taxation is a separate story. Switzerland is not part of the EU or the common VAT system, and it has its own value-added tax and rules. If the destination imposes any obligation (for example, a self-assessment mechanism for the Swiss client, or registration thresholds there), or if you want to invoke the double-taxation treaty between Spain and Switzerland, that is governed by Swiss law and the applicable treaty, outside the scope of this guide. For recurring or high-value work, confirm it with your adviser.

The nuance that can change everything: special rules and effective use

The general destination rule has exceptions worth checking before you conclude “no VAT”. Article 70 of Law 37/1992 sets out special place-of-supply rules: services connected with real estate located in Spain, transport, event access, catering and others may be located in Spain even if your client is Swiss. And there is the “effective use and enjoyment” clause in art. 70.Dos: certain services that would be located outside the EU can be “pulled back” into Spanish VAT if they are effectively used or exploited within the scope of the tax.

For a professional service consumed by a Swiss client in their own market, none of these exceptions normally applies. But it is the nuance to review before issuing, especially if your service has a real connection to use in Spain. When in doubt, check with your adviser or the “Localizador” tool on the AEAT electronic office.

Common mistakes

• Treating Switzerland like an EU client. No reverse charge, no VIES, no modelo 349: it is a third country. Putting a Swiss invoice on the 349 is a classic error.
• Saying “exempt” when it is “not subject”. This is not cosmetic: a limited exemption would cost you deduction, whereas a non-subject operation with the right to deduct (art. 94.Uno.2º) keeps it intact.
• Adding a reverse-charge note. It does not apply to a third-country client; that note is for recipients liable for Spanish VAT.
• Forgetting to convert to euros. Even if you charge in francs, the euro base (accrual-date exchange rate, art. 79.Once) is what goes on the 303, your income tax and your books.
• Thinking “no VAT” means “no invoice”. The invoice is mandatory even when not subject (art. 2 of RD 1619/2012), and income tax on that income does not disappear either.
• Assuming “no VAT” without checking art. 70. Real estate in Spain, an event, or effective use in Spanish territory can shift the place of supply.

Invoicing Switzerland, without the tedious part

The manual flow — confirming the operation is not located in Spain, adding the right note, an invoice in francs with its euro equivalent, the date’s exchange rate, carrying the base into the 303 without counting it as output VAT — is exactly where errors creep in. Frihet recognizes your operations with clients outside the EU from your own invoices (non-EU client, no VAT by place-of-supply), applies the correct reference, stores the amount in francs alongside its euro equivalent at the date’s 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, on the AEAT electronic office with your certificate. You review and file.

Executive summary (valid in 2026)

1. Place of supply: a B2B service to a Swiss company is located at destination (art. 69.Uno.1º of Law 37/1992). No Spanish VAT.
2. Not subject, not exempt: you keep the right to deduct input VAT (art. 94.Uno.2º). That is what makes it “exporting services”.
3. Nothing intra-EU: no modelo 349, no EU VAT number/VIES, no ROI (arts. 78 and 79 of RD 1624/1992).
4. Invoice: mandatory even when not subject (art. 2 of RD 1619/2012); no VAT amount and no reverse-charge note. You can issue it in Swiss francs.
5. Euros for your returns: convert the base at the accrual-date exchange rate (art. 79.Once). The income is taxed in your Spanish income tax and the Swiss client does not withhold (art. 76 of RD 439/2007).

The first invoice to Switzerland takes a little preparation. After that, it is routine.