Intra-EU VAT · Modelo 349

Modelo 349: the guide for freelancers with EU clients

If you invoice businesses in another EU country without VAT, or buy from them, those operations are reported in the 349. You pay nothing, but there are codes, deadlines and penalties. Here is what the rules say, with worked examples.

Updated 19 Oct 202610 min readChecked against the BOE
YOU · SPAINES12345678ZROI registeredCLIENT · EUDE123456789VAT ID valid in VIESInvoice0% VATMODELO 349code S · €2,000to HaciendaTHEIR TAX AUTHORITYVAT at destinationcross-checkInformational: no payment or refund
0 €to pay: it is an informational return
E · S · A · Ithe four usual codes
50.000 €threshold for the quarter and the previous 4
1–20days of the following month (January: until the 30th)
The basics

What Modelo 349 is and what it is for

Modelo 349 is the recapitulative return of intra-EU operations. In it you tell Hacienda, for each business you deal with in another Member State, the total taxable base of your supplies of goods, services and acquisitions. It is the data that lets Hacienda cross-check your return against the other country's: if they do not match, an enquiry may follow.

YOU · SPAINES12345678ZROI registeredCLIENT · EUDE123456789VAT ID valid in VIESInvoice0% VATMODELO 349code S · €2,000to HaciendaTHEIR TAX AUTHORITYVAT at destinationcross-checkInformational: no payment or refund
A VAT-free invoice to a German client: you report the operation in the 349 and Hacienda cross-checks it with the other country's authority.
What goes in and what doesn't

What you report: codes E, S, A and I

Under article 79 of the VAT Regulation, four types of operation are reported (there are rarer ones, such as triangular operations or call-off stock). The code in the form depends on whether you sell or buy and whether it is goods or services:

Is the other party in another EU country?UK, USA or Canary Islands: noYesNoNot in Modelo 349export / outside the EUIs it a business with a VAT ID?Check it in VIESNoConsumer (B2C)not in; check OSSYesWhat are you doing with it?EYou sell goodsexempt supply, art. 25 LIVASYou sell serviceslocated in their countryAYou buy goodsintra-EU acquisitionIYou buy servicesreverse charge
Does it go in the 349 and under which code? Follow the tree from top to bottom.
CodeOperationCondition under the Regulation
EIntra-EU supply of goodsExempt under art. 25 LIVA, to a recipient with a VAT ID from another Member State who has given you that number.
SIntra-EU supply of servicesNot treated as supplied in Spain, taxable and not exempt in the other State, the recipient is a business there and is the one accounting for the VAT.
AIntra-EU acquisition of goodsSubject to Spanish VAT and made by someone VAT-registered in Spain.
IIntra-EU acquisition of servicesTaxable and not exempt in Spain, supplied by someone established in the EU outside Spain, with reverse charge.
Goes in the 349
  • Design, consulting or software to a business in Germany, France, Ireland…
  • Sale of goods to an EU business with a valid VAT ID
  • Purchases from EU suppliers with reverse charge
Does not go in the 349
  • Spanish clients
  • Clients outside the EU: UK, USA, Switzerland…
  • EU consumers (B2C) and supplies to recipients with no VAT ID
  • Services that are exempt in the client's country
  • Operations with the Canary Islands, Ceuta or Melilla
Before your first invoice

ROI, VAT ID and VIES: the right order

To deal with EU businesses without charging VAT you must be registered in the Intra-EU Operators Register (ROI), requested with Modelo 036. In Spain your VAT ID is your NIF preceded by “ES”; Hacienda does not assign a separate number. And your client must have a valid VAT ID from their country, which you check in VIES.

  1. Register in the ROI with Modelo 036 (box 582), before your first EU operation.
  2. Your VAT ID is your NIF with the ES prefix. Give it to your clients to use on their invoices.
  3. Before each new client, validate their VAT ID in VIES and keep a screenshot.
  4. Issue the invoice without VAT with the right mention (see below) before the 16th of the month after the VAT accrual.
  5. Report the operation in the period's 349 and reflect it in the 303.
The invoice

How to invoice an EU client

The treatment depends on whether you sell goods or services, and the invoice mention changes. You must include your NIF and the client's VAT ID and, when the recipient is a business, issue it before the 16th of the month following the accrual (art. 11 of the Invoicing Regulation).

S
Services to an EU businessThey are not taxable in Spain under the place-of-supply rules (art. 69 LIVA). The client accounts for the VAT, so the invoice carries the mention “reverse charge” (art. 6.1.m of the Invoicing Regulation).
E
Goods to an EU businessExempt supply under art. 25 LIVA: the invoice states the operation is exempt, citing the provision (art. 6.1.j), and the client's VAT ID is mandatory.
ClientMuster GmbH · DE123456789
DescriptionWeb design services
Taxable base€2,000.00
VAT (reverse charge)€0.00
Invoice total€2,000.00
Line in the 349DE123456789 · code S · €2,000.00

Amounts in euros; if you invoice in another currency, the base is converted at the rate on the accrual date (art. 80 of the VAT Regulation).

Calendar

Deadlines and frequency: monthly or quarterly

The general rule in art. 81 of the VAT Regulation is monthly filing. You are quarterly if neither the current quarter nor each of the four previous ones exceeds €50,000 (excluding VAT) between supplies of goods that must be reported and intra-EU supplies of services. Acquisitions and purchases do not count towards that threshold.

025 k50 k€50,000 threshold12 k3T 25Quarterly18 k4T 25Quarterly22 k1T 26Quarterly56 k2T 26Monthly31 k3T 26Monthly20 k4T 26Monthly15 k1T 27Monthly9 k2T 27Monthly8 k3T 27Quarterlyover €50,000monthly: next 4 quartersquarterly
Example: in 2Q 26 you exceed €50,000 and become monthly; you return to quarterly in 3T 27, once the quarter that exceeded the threshold is outside the previous four.
PeriodQuarterlyMonthly
January–March / January1–20 April1–20 February
April–June / April1–20 July1–20 May
July–September / July1–20 OctoberAugust and 1–20 September
October–December / December1–30 January1–30 January
Two returns, one operation

349 and 303: not the same thing, and they must match

Modelo 349Modelo 303
NatureInformational (recapitulative)VAT self-assessment
Payment?NoYes, or refund or carry-forward
What it coversOnly EU operations, by operator and codeAll operations in the period
FrequencyMonthly or quarterly depending on the thresholdMonthly or quarterly depending on your regime
Who cross-checksHacienda, with the other Member StateHacienda, with the 349 and invoices
What goes wrong most

Six common mistakes and how to avoid them

1

Invoicing without VAT without being in the ROI

Register with Modelo 036 before your first EU operation. Without it you lack the identification that lets you operate and report these operations.

2

Not validating the client's VAT ID in VIES

For supplies of goods, the exemption depends on the buyer having a VAT ID from another Member State. Validate it before invoicing and keep the check.

3

Including consumers or clients outside the EU

Only operations with EU businesses or professionals are reported. End consumers and clients from the UK or the USA do not go in the 349.

4

Forgetting purchases under codes I and A

A €300 purchase from an EU-based supplier who invoices you without VAT must be reported too. Review your expenses with reverse charge.

5

Miscalculating the €50,000 threshold

The threshold looks at the quarter and the previous four, only sales and services supplied count (not purchases), and it is calculated excluding VAT. Exceeding it once keeps you monthly for four more quarters.

6

Using different amounts in the 349 and the 303

Convert to euros at the accrual-date rate and use the same base in both returns. If you change an invoice, correct both.

If something goes wrong

Penalties and how to fix a mistake

SituationWhat the law provides
Not filing on timeMinor infringement under art. 198 LGT: €200 fixed or, for informational returns, €20 per data item with a €300 minimum and a €20,000 maximum.
Filing late without a requestHalf of that penalty and of its limits (art. 198.2 LGT).
Filing with incomplete or inaccurate dataSerious infringement under art. 199 LGT: €150 fixed or €200 per data item, depending on the case.
Unreported supplies of goodsThe VAT exemption is conditional on having included them in the recapitulative return (art. 25.Uno LIVA).

The exact amount that applies to your case is for the tax authority to decide; if you received an enquiry or made a mistake, review it and ask an advisor. To correct a data item, art. 80.2 of the VAT Regulation says it is rectified in the return for the period in which the change is notified or detected.

Common questions

Frequently asked questions

Does Modelo 349 mean paying Hacienda?
No. It is an informational (recapitulative) return: no payment or refund. It lets Hacienda cross-check your operations against what the other party reports in their country.
Who has to file it?
Businesses and professionals who make intra-EU supplies or acquisitions of goods, or intra-EU supplies or acquisitions of services (arts. 78 and 79 of the VAT Regulation). There is no minimum amount: a single operation must be reported in its period.
I invoice an EU consumer. Does it go in the 349?
No. Only operations with businesses or professionals (or legal persons with a VAT ID from their country) are reported. Sales to end consumers do not go in the 349; depending on the case they may fall under the one-stop shop (OSS).
Do UK clients go in the 349?
No: since 1 January 2021 the UK is not a Member State. There is a nuance for supplies of goods to Northern Ireland, which follow EU rules (VAT numbers with the XI prefix); if that is your case, confirm it with an advisor.
Do purchases from EU suppliers go in too?
Yes, with codes A (goods) or I (services). For services, only when the supplier is established elsewhere in the EU, the operation is taxable and not exempt in Spain, and you are the one accounting for VAT (reverse charge). A subscription to a supplier based in Ireland invoiced without VAT, for example, goes under code I; one from a US supplier does not.
Is annual filing still possible?
No. The option to file the 349 once a year was abolished on 1 March 2020 (Royal Decree-law 3/2020). The return is now quarterly or monthly.
When is it monthly and when quarterly?
Quarterly if neither the current quarter nor each of the previous four exceeds €50,000 (excluding VAT) in supplies of goods and services to the EU. If you exceed it, you move to monthly. Purchases do not count towards that threshold.
What if I have no operations in a period?
If you made no operation that has to be reported in that period, there is nothing to file.
What if I don't file or I get it wrong?
There are penalties (see below). Also, for supplies of goods the VAT exemption is conditional on having included them in the recapitulative return (art. 25.Uno LIVA). If you make a mistake, you correct it in the return of the period in which you spot it.
Autónomo Simple

Work with Europe without fearing the 349

Invoice, track your costs and keep the 349 and 303 consistent in one place, with deadline reminders before each one falls due.

No card to start. Afterwards: €8.26/mo + VAT (€10 incl. VAT).

  • EU operations grouped by VAT ID and code
  • Models 303 and 349 consistent with each other
  • Invoices and costs in order, with AI receipt scanning
  • Deadline reminders so you never miss one

Official sources

General, indicative information as of 19 October 2026, based on the consolidated BOE text. It does not replace advice on your case: if in doubt, check it and ask an advisor.

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