How to invoice a UK client from Spain (2026)

You have landed a UK client, agreed the scope and the rate, and then the first invoice stalls on the VAT line. Short answer: there is no VAT line. If you are a freelancer or company based in Spain and you bill a service to a UK business client, you issue the invoice with no Spanish VAT. Since Brexit, the United Kingdom has been a third country as of 1 January 2021; under the general place-of-supply rule for B2B services (art. 69.Uno.1º of Law 37/1992), the service is deemed supplied where the client is established, so the operation is out of scope of Spanish VAT. And here is what almost nobody explains well: this is no longer an intra-community operation. No modelo 349, no NIF-IVA, no VIES registration, no IRPF withholding, and you can get paid in pounds. The nuance worth checking before you issue, though after the 2023 reform it barely touches B2B professional services, is the effective-use rule of art. 70.Dos.

Brexit changed everything: the UK is a third country

It starts with a date. With the UK’s departure from the EU and the end of the transition period, the United Kingdom became a third country for VAT purposes as of 1 January 2021. From then on, the intra-community machinery — VIES, NIF-IVA, modelo 349, the EU reverse-charge mechanism — stops applying. In its place come the place-of-supply rules of articles 69 and 70 of Law 37/1992, read now on the premise that the UK is not part of the EU.

One important note: Northern Ireland keeps a special status under the Protocol, but only for goods. For services — the subject of this guide — the UK as a whole is a third country, without exception.

Why the invoice carries no Spanish VAT

For services between businesses (B2B), VAT is paid — where due — in the client’s country, not in the supplier’s. Article 69.Uno.1º of Law 37/1992 sets it out: a service supplied by a Spanish business to a business established outside the territory where the tax applies is deemed supplied at the recipient’s location. If that location is the UK, the operation is located there and is out of scope of Spanish VAT. The Spanish tax authority confirms this treatment for outbound services. The invoice therefore goes out at zero, with no VAT amount.

It is worth drawing a distinction that confuses many people: this is a non-subjection by place of supply, not the “exempt export” that applies to goods physically leaving the EU (that is a separate figure, art. 21 of Law 37/1992). With services we are not talking about exporting merchandise, but about where the service is deemed to be consumed. We develop the general circuit for non-EU clients in the guide to exporting services outside the EU.

Not intra-community: no modelo 349, no VIES, no NIF-IVA

The number-one mistake when invoicing the UK after Brexit is to keep treating it as you did when it was an EU client. It no longer is: it is a third country, and the whole intra-community apparatus does not apply:

• No modelo 349. Since 1 January 2021, operations with the UK stopped being intra-community and are not reported on the recapitulative statement. When that form does apply to EU clients is covered in our guide to modelo 349.
• No NIF-IVA and no VIES. The NIF-IVA and the 349 reporting are only required for operations with other EU member states, not third countries. You do not validate your UK client in VIES.
• You invoice against their UK tax identification. Instead of a VIES-verifiable VAT number, you record the name, address and tax identification of the client in the UK (their UK VAT number or company number).

What you do keep is the right to deduct: even though your invoice goes out at zero, art. 94 of Law 37/1992 preserves the right to deduct input VAT on the expenses tied to that activity, exactly as if the operation had taken place in Spain. Since you charge zero and deduct everything, your modelo 303 will often come out in a credit or refund position.

What the invoice must say

An invoice to a UK client is almost identical to a domestic one, but with two differences: no VAT amount, and it is good practice to include the reason no VAT is charged.

Field	Domestic invoice	Invoice to a UK company
VAT rate	21% / 10% / 4%	No VAT (out of scope by place of supply)
VAT amount	Calculated	0.00
Currency	Euros	Euros or pounds (your choice)
IRPF withholding	Per activity	None
Legal note	Not required	Reference to the non-subjection

There is always an obligation to issue an invoice: art. 2 of RD 1619/2012 requires invoicing for services, “including those out of scope and those subject but exempt,” and in any case when the recipient is a business or professional.

On the note, a useful technical nuance: art. 6.1.j) of RD 1619/2012 requires a statutory reference when the operation is exempt. An invoice to the UK is not an exemption but a non-subjection by place of supply, for which the mention is not a strict formal requirement; even so, it is best practice for traceability in an audit. A common, valid wording:

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

The general mandatory content (number and series, dates, both parties’ details, description and taxable base) is covered field by field in our invoicing guide for freelancers in Spain.

Invoicing in pounds: currency and exchange rate

You can issue the invoice directly in pound sterling (GBP). The Spanish invoicing regulation (RD 1619/2012) allows amounts to be expressed in any currency; the only condition is that, if VAT were charged, that amount is also expressed in euros using the exchange rate of art. 79.Once of Law 37/1992 (the rate in force at the moment the tax accrues). Since your UK invoice carries no VAT in the general case, there is no amount to convert.

That said, even when you get paid in pounds, the taxable base must be converted to euros — at the exchange rate on the operation date — for your modelo 303, your IRPF return and your accounting. Record the euro equivalent and the rate applied on the invoice itself or in its ledger. If you invoice regularly in several currencies, we cover exchange differences in the guide to invoicing in multiple currencies from Spain.

Worked example

A Spanish consultancy supplies a strategy service to a London company for GBP 4,000. For illustration, assume an exchange rate on the accrual date of 0.85 GBP per euro (always use the real rate for your date):

Item	Amount
Consulting services	GBP 4,000.00
VAT (out of scope by place of supply)	0.00
IRPF withholding	0.00
Total to collect	GBP 4,000.00
Euro equivalent of the base (example, 0.85)	EUR 4,705.88

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

The UK client pays GBP 4,000 in full. You remit no VAT, but you record EUR 4,705.88 of base (per your real date’s rate) for the 303 and your IRPF: on the 303 it is reported as an operation out of scope under the place-of-supply rules, with the right to deduct. Where exactly it goes is covered in the step-by-step modelo 303 guide.

No IRPF withholding: you collect in full

That the invoice carries no VAT does not mean the income is tax-free: the income is still taxed. But the invoice carries no IRPF withholding, because the duty to withhold falls on payers established in Spain, and a non-resident UK client with no permanent establishment in Spain is not among the parties required to withhold under art. 76 of the IRPF regulation (RD 439/2007). The payment reaches you in full.

The contrast helps fix it: that same activity, billed to a Spanish client, would carry withholding (for example, the general 15% or the 7% for new freelancers); to a UK client, it does not. But the income still enters your IRPF, through your quarterly instalment payments and your annual return. What disappears is the VAT amount and the withholding, not income tax.

The exception that remains after the reform: leasing of means of transport

Article 70 of Law 37/1992 sets out special place-of-supply rules and, in particular, the effective use or enjoyment rule in its paragraph Two (art. 70.Dos): for certain services, if the operation would be located outside the EU — in the UK — but the service is actually used or exploited within the territory where the tax applies (mainland Spain and the Balearic Islands), that rule can pull the operation back into Spanish VAT. Until the Ley 31/2022 reform (in force since 1 January 2023), this rule could reach certain intangible B2B services (advertising, consultancy, intermediation…). The reform removed that route for B2B operations that generate the right to deduct — the usual case for a professional service — precisely to avoid penalising the competitiveness of these services against non-EU suppliers. The intangible services in art. 70.Dos.1º are now pulled back only when the recipient is a final consumer (B2C), not a business.

For a UK business client, the only thing that still applies is paragraph 70.Dos.2º: the leasing of means of transport. If your service is not that, the effective-use rule does not touch you. Even so, as good practice — especially if you have doubts about the nature of your service — check the case against the AEAT’s online place-of-supply locator (“Localizador de prestaciones de servicios”) before issuing. If it applied, you would charge Spanish VAT, expressed in euros using the exchange rate of art. 79.Once.

Common mistakes

• Still treating the UK as an EU client. It has been a third country since 1 January 2021: no VIES, NIF-IVA or modelo 349. Putting a UK invoice on the 349 is the classic post-Brexit error.
• Charging Spanish VAT “just in case.” If the operation is located at destination, charging VAT distorts the invoice and forces a correction.
• Assuming the effective-use rule (art. 70.Dos) still touches any B2B professional service. Since the 2023 reform it only reaches, in B2B, the leasing of means of transport; other intangible services only apply to final consumers (B2C). Checking the case in the locator is still good practice.
• Adding IRPF withholding. The UK client is not required to withhold; the invoice goes out with none and you collect in full.
• Forgetting to convert to euros. Even when paid in pounds, the euro base (exchange rate on the operation date) is what feeds the 303, your IRPF and your accounting.
• Confusing services with goods. Selling merchandise is a VAT-exempt export (art. 21) with a DUA, and Northern Ireland is treated as EU only for goods: a different regime.

Invoicing the UK, without the tedious part

The manual flow — the correct legal note, an invoice in pounds with its euro equivalent, the exchange rate on the date, carrying the base into the 303 without double-counting, checking you do not put the operation on the 349 — is exactly where errors creep in. Frihet detects your operations with non-EU clients from your own invoices, applies the correct non-subjection note, stores the pound amount alongside its euro equivalent, and reuses that base to build the modelo 303 preview.

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

Executive summary (current for 2026)

1. Brexit: the UK is a third country for VAT as of 1 January 2021. It is no longer intra-community.
2. Place of supply: B2B service to a UK company → located at destination (art. 69.Uno.1º of Law 37/1992). No Spanish VAT (non-subjection, not exemption), and no modelo 349 or NIF-IVA/VIES.
3. No IRPF withholding: a non-resident client with no permanent establishment in Spain does not withhold (art. 76 of RD 439/2007). You collect in full.
4. Currency and exception: you can invoice in pounds (convert the base to euros for your returns) and check the effective-use rule (art. 70.Dos) in the AEAT locator before issuing.

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