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.
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.
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:
| Code | Operation | Condition under the Regulation |
|---|---|---|
| E | Intra-EU supply of goods | Exempt under art. 25 LIVA, to a recipient with a VAT ID from another Member State who has given you that number. |
| S | Intra-EU supply of services | Not 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. |
| A | Intra-EU acquisition of goods | Subject to Spanish VAT and made by someone VAT-registered in Spain. |
| I | Intra-EU acquisition of services | Taxable and not exempt in Spain, supplied by someone established in the EU outside Spain, with reverse charge. |
- 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
- 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
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.
- Register in the ROI with Modelo 036 (box 582), before your first EU operation.
- Your VAT ID is your NIF with the ES prefix. Give it to your clients to use on their invoices.
- Before each new client, validate their VAT ID in VIES and keep a screenshot.
- Issue the invoice without VAT with the right mention (see below) before the 16th of the month after the VAT accrual.
- Report the operation in the period's 349 and reflect it in the 303.
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).
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).
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.
| Period | Quarterly | Monthly |
|---|---|---|
| January–March / January | 1–20 April | 1–20 February |
| April–June / April | 1–20 July | 1–20 May |
| July–September / July | 1–20 October | August and 1–20 September |
| October–December / December | 1–30 January | 1–30 January |
349 and 303: not the same thing, and they must match
| Modelo 349 | Modelo 303 | |
|---|---|---|
| Nature | Informational (recapitulative) | VAT self-assessment |
| Payment? | No | Yes, or refund or carry-forward |
| What it covers | Only EU operations, by operator and code | All operations in the period |
| Frequency | Monthly or quarterly depending on the threshold | Monthly or quarterly depending on your regime |
| Who cross-checks | Hacienda, with the other Member State | Hacienda, with the 349 and invoices |
Six common mistakes and how to avoid them
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.
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.
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.
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.
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.
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.
Penalties and how to fix a mistake
| Situation | What the law provides |
|---|---|
| Not filing on time | Minor 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 request | Half of that penalty and of its limits (art. 198.2 LGT). |
| Filing with incomplete or inaccurate data | Serious infringement under art. 199 LGT: €150 fixed or €200 per data item, depending on the case. |
| Unreported supplies of goods | The 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.
Frequently asked questions
Does Modelo 349 mean paying Hacienda?
Who has to file it?
I invoice an EU consumer. Does it go in the 349?
Do UK clients go in the 349?
Do purchases from EU suppliers go in too?
Is annual filing still possible?
When is it monthly and when quarterly?
What if I have no operations in a period?
What if I don't file or I get it wrong?
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
- BOEVAT Regulation (RD 1624/1992), arts. 78-81 — recapitulative return
- BOEVAT Law, art. 25 (exempt supplies to another Member State) and art. 69 (place of supply of services)
- BOERoyal Decree-law 3/2020 — abolishes annual filing of the 349 (art. 216)
- BOEInvoicing Regulation (RD 1619/2012), arts. 6 and 11
- BOEGeneral Tax Law, arts. 198 and 199 — penalties
- AEATAEAT — Modelo 349
- AEATAEAT — Intra-EU operators (ROI) and EU operations
- UEEuropean Commission — VIES (VAT ID validation)
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.