EU REGULATORY GUIDE

The Solopreneur’s Guide to EU VAT Reverse-Charge (Article 196)

How to invoice cross-border clients across the EU and internationally without risking audit penalties or charging incorrect VAT.

The 3 Rules of Cross-Border EU Invoicing

1. Billing US, UK, or Non-EU Clients (Export of Services)

Under the EU VAT territoriality rules (Directive 2006/112/EC), services performed for clients established outside the European Union are out of the scope of EU VAT. You bill at 0% VAT and must include this required note:
"Service rendered to a recipient established outside the EU. Export of services outside the territorial scope of EU VAT."

2. Billing B2B Clients in Another EU Country (Reverse-Charge)

Under Article 196 of Council Directive 2006/112/EC, the liability to pay VAT shifts to the customer in their member state. You charge 0% VAT, but you must:

  • Verify their VAT identification number in the official EU VIES database.
  • Include both your VAT ID and the client's VAT ID on the invoice.
  • Include the mandatory statement: "Reverse charge: VAT to be accounted for by the recipient as per Article 196 of Council Directive 2006/112/EC."
  • Report the transaction in your quarterly Recapitulative Statement (ZM).

3. Billing Domestic Clients

For clients inside your own tax residence country, standard national VAT applies (e.g. 19% in Germany, 21% in Spain, 20% in France).

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