This guide explains when a freelancer (autónomo) in Spain can issue an invoice without VAT, how the template works, and what you must write to make it valid. It also shows how the new VeriFactu rules will affect even VAT-free invoices.

‍

FAQ

Can I issue invoices without VAT?
Yes, but only if the law says the service is exempt or not subject to VAT.

Do I need a separate template?
No. You use the same structure as any invoice. You only add a short legal note that explains why VAT is not applied.

Does VAT-free mean no IRPF?
No. If your activity requires IRPF withholding, you must include it even when VAT is not charged.

Does VeriFactu affect VAT-free invoices?
Yes. All invoices will follow the new electronic rules.

‍

Invoice Template Without VAT in Spain - quick overview

A VAT-free invoice is a normal invoice where VAT does not appear. The reason is simple: the law allows you to omit VAT in specific situations.

The layout stays the same. The only change is on the VAT line:

• Charge VAT at 0 %, or
• Remove the VAT line and add a legal explanation

You cannot skip VAT because you want to. It must meet the legal criteria.

‍

Cases where VAT can be omitted

You can issue an invoice without VAT in two types of situations. This distinction matters.

Exempt operations

These services normally have VAT, but the law creates an exemption. VAT exists in theory, but you charge 0 %.

Typical cases for freelancers:

• Private teaching that meets the education exemption
• Health services by authorised professionals
• Some cultural or social services
• Some financial services
• Housing rentals

Not-subject operations

These services fall outside the VAT rules. VAT never applies because the operation does not meet the legal conditions for VAT.

Typical cases:

• Services to EU companies with a valid VAT number (reverse charge)
• Services to non-EU clients
• Export of goods
• Some international consulting services

If you issue a VAT-free invoice when VAT should be charged, you face penalties and interest. Check your activity, the type of client, and the place where your service is considered provided.

‍

‍

Invoice Template Without VAT - what it must include

A VAT-free invoice must include the same elements as a standard invoice (see the basics in How to make an invoice):

• The word “Factura”
• Invoice number and series
• Date
• Your details: name, NIF, address
• Client details: name, NIF, address
• Description of the service
• Quantity or hours, unit price, subtotal

Then add the legal VAT explanation. Use one of these options:

• “IVA 0 %”
• “Operación exenta de IVA - art. 20 Ley 37/1992”
• “Operación no sujeta - art. 69 Ley 37/1992”

If your professional activity requires IRPF withholding, add it:

• Example: IRPF 15 % for professional services

The total will match the subtotal if no VAT is charged.

‍

Examples inspired by the structure in the renn “Invoice Request” guide

Below are short examples following the style of the invoice-request article.

Example 1: Education service - exempt

• Concept: 10 hours of English classes
• Unit price: 20 euros
• Subtotal: 200 euros
• VAT: Operación exenta de IVA - art. 20 Ley 37/1992
• IRPF: 0 %
• Total: 200 euros

Example 2: Service to EU company - not subject

• Concept: Website design for a German company with EU VAT number
• Subtotal: 1.000 euros
• VAT: Operación no sujeta a IVA - art. 69 Ley 37/1992 (reverse charge)
• IRPF: 15 %
• Total: 850 euros

Example 3: Service to non-EU client - not subject

• Concept: Consulting service to a US client
• Subtotal: 500 euros
• VAT: Operación no sujeta a IVA por regla de localización
• IRPF: 15 %
• Total: 425 euros

These examples follow what the tax agency expects: simple, clear, with the legal note included.

‍

VeriFactu and the shift to mandatory electronic invoicing

Spain will require electronic invoicing under VeriFactu, based on Real Decreto 1007/2023. VeriFactu is a digital system that ensures each invoice is created in certified invoicing software, saved in order, and cannot be changed in secret.

These rules apply to every invoice, including VAT-free invoices. PDF files made manually will not meet the standard. You will need invoicing software that creates invoices in a secure, traceable digital format.

Tools like renn already include electronic invoicing aligned with these rules. This means freelancers can issue VAT-free invoices and be prepared for VeriFactu without changing their workflow.

‍

Bottom line

A VAT-free invoice is allowed only when the service is exempt or not subject by law. The template is the same as any normal invoice, but you must add the legal explanation. With VeriFactu coming, all invoices must be electronic, traceable, and created in certified software. Using proper invoicing tools helps you avoid mistakes and stay compliant from the start.