Meta, Google and Shopify invoices without VAT: the reverse charge and Form 349

You pay for ads, your store subscription or some software, the invoice arrives and there is no VAT (IVA) on it. It looks like a saving, but it isn't: if the invoice comes from a business in another EU country, the VAT has not gone away. You have to declare it yourself. This is called the reverse charge («inversión del sujeto pasivo»), and it is easy to miss.

The good news is that in the normal case you pay nothing extra: the same VAT you declare, you deduct at the same time. But it has to be declared, on Form 303 and on Form 349, and for that you need to be on the Register of Intra-Community Operators (ROI).

1. Why the invoice has no VAT

If the invoice comes from a business in another EU country without VAT, the explanation is in two articles of the Spanish VAT Act:

• Where the service is treated as supplied. Between businesses, the service is treated as supplied where the customer is: article 69.Uno.1.º places it in Spain «Cuando el destinatario sea un empresario o profesional que actúe como tal y radique en el citado territorio la sede de su actividad económica» (when the customer is a business acting as such with its seat in Spain). If your business is in Spain, the service is taxed in Spain.
• Who pays the VAT. Because the business invoicing you is not established in Spain, you are the one who declares the VAT. Article 84.Uno.2.º makes the business customer liable when the supplies «se efectúen por personas o entidades no establecidas en el territorio de aplicación del Impuesto» (are made by persons or entities not established in Spain's VAT territory).

Don't go by the brand name to work out where you are being invoiced from. Look at the invoice itself: who issues it, which country they are in, what VAT number they have and whether VAT is charged.

2. What goes on Form 303

You declare it twice on the same Form 303, according to the Spanish Tax Agency's (AEAT) official 2026 instructions:

• Boxes 10 and 11, in output VAT: «las bases imponibles gravadas correspondientes al total de adquisiciones intracomunitarias de bienes y servicios realizadas en el período de liquidación, y la cuota resultante» (the taxable bases of all intra-Community acquisitions of goods and services in the period, and the resulting tax). This is the VAT you charge yourself.
• Boxes 36 and 37, in deductible VAT: the official 2026 record layout for the form calls them «En adquisiciones intracomunitarias de bienes y servicios corrientes» (ordinary intra-Community acquisitions of goods and services). This is where you deduct that same VAT. The law allows the tax on supplies under article 84.Uno.2.º to be deducted (article 92.Uno.3.º).

If the service is linked to your business and you can deduct all your VAT, both amounts are equal and the effect on what you pay is zero. But both must be there. If your business cannot deduct all its VAT, the result is no longer zero: check it with your accountant (gestor).

3. An example with numbers

These figures are an example. A business in another EU country invoices you €100.00 for advertising, without VAT. The service is taxed in Spain at 21%.

Where	Item	Base	Tax
303, boxes 10 and 11	VAT you charge yourself	€100.00	€21.00
303, boxes 36 and 37	Deductible VAT	€100.00	€21.00
	Net effect on Form 303		€0.00
349, key I	Base of the service received	€100.00

The cost to your business is the €100.00 you paid. The VAT goes in and out of Form 303 without changing the result.

4. Form 349: key I

As well as Form 303, these services go on Form 349, the return for transactions with other EU countries. The Spanish VAT Regulation requires it from anyone receiving «Las adquisiciones intracomunitarias de servicios» (intra-Community acquisitions of services) supplied by an EU business outside Spain when «el sujeto pasivo sea el destinatario» (the customer is the person liable for the tax, article 79.1.4.º).

• The key is I. The Form 349 instructions describe it as «I: Adquisiciones intracomunitarias de servicios localizadas en el TAI prestadas por empresarios o profesionales establecidos en otros EM cuyo destinatario es el declarante» (intra-Community acquisitions of services taxed in Spain, supplied by businesses established in other Member States to the person filing).
• Only the base goes on it, never the VAT: according to the instructions, you enter the details of suppliers and customers «así como la base imponible relativa a las operaciones intracomunitarias declaradas» (as well as the taxable base of the intra-Community transactions declared).
• Quarterly or monthly. According to the instructions, it is filed quarterly when neither the quarter nor any of the four previous ones exceeds €50,000 without VAT of reportable transactions; otherwise, monthly. Quarterly filing: April, July and October: up to the 20th; the fourth quarter in January: up to the 30th.

5. The ROI: your EU VAT number

To receive these services under the reverse charge you need an EU VAT number, which is your Spanish tax ID (NIF) with the ES prefix. The Spanish tax management regulation says it is assigned to «Los empresarios o profesionales que sean destinatarios de servicios prestados por empresarios o profesionales no establecidos en el territorio de aplicación del Impuesto» (businesses receiving services from businesses not established in Spain) for which they are liable (article 25.2.b), and that it is assigned when you apply to be included on the Register of Intra-Community Operators (article 25.1).

If you are not on the ROI and you pay EU businesses for advertising, software or subscriptions, talk to your accountant without delay.

6. Cases that are not this one

• The invoice has Spanish VAT on it. Then it is an ordinary expense: its VAT goes in boxes 28 and 29 of Form 303 and it does not go on Form 349.
• The invoice comes from outside the EU. It is not an intra-Community acquisition, so it does not go on Form 349 or in boxes 10 and 11. The Form 303 instructions send other reverse-charge transactions to boxes 12 and 13. Check the case with your accountant.
• You are under the equivalence surcharge (recargo de equivalencia). Your case is different from the one in this article. Check it with your accountant.

Summary

1. Look at the invoice: if it comes from a business in another EU country without VAT, you declare the VAT.
2. On Form 303: base and tax in boxes 10 and 11, and the same deduction in boxes 36 and 37.
3. On Form 349: the base, under key I.
4. For all of this you need to be on the ROI.

To see all your quarter's expenses and sales in one place, have a look at the demo or try Plentia free for 14 days, no card needed.

Sources

• BOE · Ley 37/1992, VAT Act (articles 69, 84 and 92) · checked on 26/09/2026
• BOE · Real Decreto 1624/1992, VAT Regulation (article 79) · checked on 26/09/2026
• BOE · Real Decreto 1065/2007, tax management and inspection regulation (article 25) · checked on 26/09/2026
• Agencia Tributaria · Form 303, 2026 instructions (boxes 10 to 13 and 28 to 39, in Spanish) · checked on 26/09/2026
• Agencia Tributaria · Form 303 record layout, 2026 (names of boxes 36 and 37, in Spanish) · checked on 26/09/2026
• Agencia Tributaria · Form 349 instructions (PDF, in Spanish) · checked on 26/09/2026