Modelo 349: the definitive guide for freelancers with EU clients
If you invoice businesses in Germany, France or any EU country, you must file Modelo 349. It's informational — no payment — but mandatory. This guide explains how it works, when to file and how to avoid penalties.
- Modelo 349 is informational — no payment or refund generated
- Required if you invoice EU businesses (not consumers, not USA/UK)
- You need ROI registration (box 582 of Modelo 036) and a VAT ID
- Invoices without VAT with 'Reverse charge' mention
- Quarterly if sales ≤€50,000/quarter · Monthly if you exceed that
- Minimum penalty for not filing: €300
What is Modelo 349?
Modelo 349 is the recapitulative declaration of intra-EU operations. It's the form you use to inform Hacienda of the purchases and sales you've made with businesses or professionals in other EU countries.
The key point: no payment is involved. Its function is to allow Hacienda to cross-reference your declaration with the equivalent declaration from the EU client — if the data doesn't match, an enquiry can follow. It's the piece that makes the intra-EU VAT system work across Europe.
Who must file it?
Any freelancer or business that performs intra-EU operations, regardless of amount. There's no minimum threshold — a single invoice to a German client triggers the filing obligation.
- ✓You sell services to EU businesses
- ✓You sell goods to EU businesses
- ✓You buy goods or services from EU suppliers
- ✓You're in the ROI with an active VAT ID
- ✗You only invoice Spanish clients
- ✗You invoice USA, UK, Swiss clients, etc.
- ✗You sell to EU individual consumers
- ✗You invoice the Canary Islands, Ceuta or Melilla
Before you start: the ROI and your VAT ID
To operate with EU clients, you need to be registered in the Registry of Intra-EU Operators (ROI). You do this by ticking box 582 in Modelo 036. Once registered, Hacienda assigns you an intra-EU VAT ID (like ES12345678A) that your EU clients need to correctly issue their invoices.
You must be registered in the ROI before issuing your first invoice to a European client. If you invoice without being in the ROI, the transaction may not be VAT-exempt and you could receive a tax bill.
The complete step-by-step process:
Box 582 — ROI registration. Before your first invoice to an EU client.
Hacienda assigns you a number like ES12345678A valid across the EU.
Use the EU VIES system. If invalid, add Spanish VAT as if a domestic client.
Include the mention 'Reverse charge' and the client's VAT number.
Quarterly (≤€50,000) or monthly (>€50,000). First 20 days of the next period.
How do you invoice EU clients?
An invoice to an EU B2B client carries 0% VAT with reverse charge. The client pays and declares VAT in their country. You report the transaction in Modelo 349.
⚠️ Always verify the client's VAT ID on VIES (ec.europa.eu/taxation_customs/vies) before issuing a zero-VAT invoice. If the VAT ID is invalid, you must add Spanish VAT.
When and how often?
The frequency depends on the volume of intra-EU sales. For most freelancers with occasional EU clients, filing is quarterly.
💡 To calculate whether you file monthly or quarterly, only <strong>sales</strong> count (deliveries and services). Purchases from European suppliers don't affect the threshold. If you only make acquisitions, you can choose the frequency freely.
Modelo 349 vs Modelo 303 — what's the difference?
Modelo 303 and 349 are complementary — both are filed the same quarter and Hacienda cross-references the data. The key difference is that 303 covers all VAT (domestic and international) while 349 only captures intra-EU operations as an informational declaration.
If in your 303 you declare €2,000 of intra-EU operations with reverse charge, the same operation must appear in the 349 with the same amount and the correct client VAT ID. Discrepancies can trigger a formal enquiry from Hacienda.
Most common mistakes — and how to avoid them
Frequently asked questions
Does Modelo 349 involve paying Hacienda?
What happens if I forget to file it?
Do I need to file 349 if I invoice EU consumers?
Do UK clients require Modelo 349?
Do purchases from EU suppliers also go in 349?
How does 349 relate to Modelo 303?
Can I skip 349 if I have no operations that quarter?
Guided Modelo 349 — box by box
When we detect reverse-charge invoices in your quarter, Modelo 349 activates automatically. Each intra-EU transaction appears pre-filled with the client's VAT ID, amount and operation type.
Do you have EU clients?
Autónomo Simple detects your intra-EU operations and handles Modelo 349 alongside Modelo 303. No double work, no errors.
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