Yes, you can issue an invoice without VAT in Spain, but only in legally defined cases. This brief explains when a zero‑VAT invoice is legal, the exact fields it must include, the legal note to add with the article number, and edge cases like intra‑EU B2B services and exports. You also get a worked example of a VAT‑exempt invoice and a ready‑to‑copy training invoice template, plus common mistakes and how to report these invoices in Modelo 303 and 390.
Quick Q&A
- Is it legal to issue invoices without VAT? Yes, when the operation is exempt, not subject, or taxed at 0% with right to deduct.
- Do I need to cite the law on the invoice? Yes. Add a short note stating the article and reason.
- Can I deduct input VAT on exempt activities? Usually no, except for exports and certain intra‑EU supplies of goods.
- Do I still need to issue an invoice? Yes, unless a specific AEAT exception applies.
Invoice model without VAT (quick start)
A zero‑VAT invoice is either exempt (exento), not subject (no sujeto, for example by place‑of‑supply rules), or 0%/exempt with right to deduct (exports and certain intra‑EU supplies of goods). The format is the same as any Spanish invoice set by RD 1619/2012: numbering, dates, parties, description, taxable base, and totals. The key difference is a short legal note that cites the legal article and explains why VAT is not applied. Zero‑VAT does not mean no invoice.
See the basics in How to make an invoice.
Is it legal to issue invoices without VAT?
Yes, but only in three buckets.
Exempt operations sit inside VAT but the law exempts them. LIVA article 20 lists the main cases. Examples: healthcare, education and training, financial and insurance intermediation, long‑term housing rentals, the postal universal service, some cultural or non‑profit events, and lotteries.
Not subject operations are outside Spanish VAT. Common cases: services whose place of supply is abroad under article 69, or the transfer of a going concern under article 7. In cross‑border B2B services, the customer usually self‑accounts for VAT in their country under reverse charge.
0% or exempt with right to deduct covers exports outside the EU and certain intra‑EU supplies of goods. The supplier invoices at 0% but keeps the right to deduct input VAT if the proof is kept.
Outside these cases, you must charge VAT at 21%, or 10% or 4% where applicable.
Exempt vs not subject vs 0%: what’s the difference?
Exempt means the deal is in VAT, but the law says do not add VAT. You generally cannot deduct related input VAT. Education and healthcare are common examples.
Not subject means the deal is outside Spanish VAT. Typical case: a Spanish freelancer sells a B2B service to a company in another EU country. The place of supply is the customer’s country. You show VAT as 0.00 and add a note that the operation is not subject in Spain by article 69. The buyer accounts for VAT at destination, if their rules say so.
0% with right to deduct is like a zero rate. It applies to exports and to intra‑EU supplies of goods to VAT‑registered buyers in other Member States. You invoice at 0%, keep the right to deduct input VAT, and keep proof of transport and the buyer’s valid VAT ID.
Mandatory fields for a zero‑VAT invoice (Spain)
Follow RD 1619/2012 article 6 for content. Include a sequential invoice number and series, the issue date, supplier NIF and address, customer details and VAT number where relevant, a clear description of goods or services, the taxable base, the VAT rate and VAT amount, and any reference to exemption or special regimes.
Add an explicit legal note when no VAT is applied. Use short, clear wording:
- Education exemption: “Operación exenta de IVA según art. 20.Uno.9/10 de la Ley 37/1992 (servicios de enseñanza).”
- Healthcare exemption: “Exento de IVA art. 20.Uno.3 LIVA (asistencia sanitaria).”
- Housing rental: “Exento de IVA art. 20.Uno.23º LIVA (arrendamiento de vivienda).”
- Not subject - B2B service to EU company: “Operación no sujeta en España por reglas de localización art. 69 LIVA. Inversión del sujeto pasivo en destino, si procede.”
- Intra‑EU supply of goods (0%): “Entrega intracomunitaria exenta art. 25 LIVA. Comprador con NIF‑IVA válido y prueba de transporte.”
- Export: “Exportación exenta art. 21 LIVA. Prueba de salida del territorio aduanero de la UE.”
When the customer is in the EU, include their VAT ID and check it in VIES. Keep contracts, transport proofs, training accreditations, or medical licenses that support the reason you used.
Example VAT‑exempt invoice (walkthrough)
Scenario. A private teacher invoices a Spanish company for a course in a curricular subject.
Header. Supplier name and address with NIF. Customer company name and address with NIF. Issue date. Invoice number and series.
Lines. “Sesiones de preparación en [materia], [fechas].” Quantity 1. Base 1,000 euros. VAT rate 0.00%. VAT amount 0.00 euros.
Legal note. “Operación exenta de IVA según art. 20.Uno.10 de la Ley 37/1992 (clases particulares de materias incluidas en planes de estudio).”
Totals and payment. Total 1,000 euros. Add payment terms and bank details. Send the PDF and save it in your sales book.
Books and returns. Mark the invoice as exempt in your sales book. Include it in Modelo 303 in the boxes for exempt outputs and in Modelo 390 in the annual totals for exempt operations. If you also sell to EU businesses, check if a Modelo 349 is due for services. Rules change, so confirm the current form labels each year.
IRPF. For Spanish clients, if your activity is a professional service, add IRPF withholding at 15%, or 7% if you are eligible for the reduced rate. No IRPF withholding applies to foreign clients.
Invoice template: training without VAT (copy‑ready)
Who can use this.
- Private teachers giving classes in school or university curriculum subjects under article 20.Uno.10.
- Education centers, public or authorized private, providing formal education under article 20.Uno.9. Recreational workshops do not qualify.
Template blocks to include.
- Title: Invoice. Number and series. Issue date.
- Supplier: name or trade name, NIF, address, email.
- Customer: name or company, NIF if company, address.
- Concept: “Curso de [asignatura] – [nº horas y fechas].”
- Base imponible: X,XXX euros.
- VAT: 0.00% – 0.00 euros.
- Legal note, choose one:
- “Operación exenta de IVA según art. 20.Uno.9 LIVA (servicios de enseñanza por centro educativo).”
- “Operación exenta de IVA según art. 20.Uno.10 LIVA (clases particulares de materias incluidas en planes de estudio).”
- Payment terms and bank details. Supplier signature if needed.
Documents to keep. Course program, proof of curricular alignment or center authorization, attendance list, and contract or order form.
Warning. If the course is a recreational or hobby workshop, like Photoshop for hobbyists, VAT will likely be 21%. Do not use the exemption.
Other common invoice without VAT scenarios
B2B services to EU companies.
No Spanish VAT. Add “Operación no sujeta art. 69 LIVA. Inversión del sujeto pasivo en destino.” Check the customer’s VAT number in VIES and store the proof. You may need to file Modelo 349 for services and to show these as not subject by localization in the 303.
Exports of goods outside the EU.
0% with right to deduct. Keep the customs DUA and transport proof.
Intra‑EU supply of goods.
0% with right to deduct. Get the buyer’s valid VAT ID and proof of transport.
Healthcare invoices.
Exempt by article 20.Uno.3. Keep your professional license or clinic documents.
Housing rentals.
Long‑term residential leases are exempt by article 20.Uno.23º.
Tourist rentals:
- Without hotel-type services and used exclusively as housing → exempt (no VAT; ITP may apply).
- With hotel-type services (cleaning during the stay, linen changes, reception, etc.) → 10% VAT (art. 91.Uno.2.2º LIVA).
- Leased to agencies/companies that don’t use the dwelling as housing → generally 21% VAT
Financial and insurance intermediation.
Exempt by article 20.Uno.16º and 20.Uno.18º. Commission invoices are at VAT 0 with the exemption note.
IRPF withholding, Modelo 303 and 390, and bookkeeping
IRPF withholding. It applies to professional services billed to Spanish businesses or professionals. Use 15%, or 7% if you qualify for the reduced rate in your first years. It still applies when the invoice is VAT‑exempt. Do not add IRPF for foreign clients.
Modelo 303. Report exempt outputs in the exentas boxes. Report not subject by localization in the no sujetas boxes. Show 0% operations with right to deduct where the form asks for operations that do not generate VAT but keep deduction rights. Check the current year labels before you file.
Modelo 390. Include the annual totals of exempt, not subject, and 0% outputs under the current headings.
Books. Record all zero‑VAT invoices in the sales book with the correct key and cause. Keep all proofs.
Frequent mistakes and how to avoid fines
- No legal reference on the invoice. Always add a short note with the article and reason.
- Using the education exemption for non‑formal courses. Check the course is curricular or the center is formal.
- Skipping IRPF withholding. Add 15% or 7% when due on professional invoices to Spanish clients.
- Not checking VIES for EU B2B. Validate the customer VAT number and keep proof of the check.
- Claiming input VAT on fully exempt activities. If you only do exempt work without deduction rights, you cannot deduct input VAT. If you have mixed activities, apply prorata.
- Treating tourist rentals as exempt housing. Most short‑term stays are subject to 21% VAT.
Avoid mistakes : Create and send invoices with renn.
Bottom line
You can issue an invoice without VAT in Spain when the law says the operation is exempt, not subject by place‑of‑supply rules, or 0% with right to deduct, such as exports and intra‑EU supplies of goods. The invoice must include all standard fields plus a short legal note that cites the LIVA article. When unsure, charge VAT and ask a tax advisor. Misuse leads to assessments and penalties. This guide and template help you issue an invoice model without VAT in Spain correctly.
