Invoicing customers outside the EU: exports, services and what to write

A customer in the United Kingdom, Switzerland or the United States is outside the EU VAT system, and the reverse charge is the wrong instrument. Depending on what you sell and to whom, the supply is either an exempt export or simply outside the scope of EU VAT — and in both cases the invoice carries no VAT, for a different reason that the document should state.

Goods: the export exemption

Goods dispatched or transported to a destination outside the EU by or on behalf of the seller, or by a non-established customer, are exempt under Article 146(1)(a) and (b) of the VAT Directive. The invoice shows no VAT and an exemption reference (Article 226(11)); the customs export declaration is your evidence, so keep the exit confirmation with the invoice. Goods a non-EU traveller carries out for private use follow the retail-export scheme instead (Article 147).

Services to a business outside the EU

General-rule services to a taxable person are supplied where the customer is established (Article 44). For a business outside the EU that place is outside the EU, so the service is outside the scope of EU VAT: no VAT, no reverse-charge mention. A note such as "Not subject to EU VAT — Article 44 of Council Directive 2006/112/EC" is customary and helpful. Check whether the customer's country levies its own VAT or sales tax on imported services; that is a question for its rules, not the Directive.

Services to a consumer outside the EU

General-rule services to a private individual are taxed where the supplier is established (Article 45), so your own VAT applies. Article 59 lists the exceptions — advertising, consultancy, legal, accounting, data processing, licensing of intellectual property, telecommunications and electronically supplied services, among others — which are supplied where the non-EU customer is and therefore outside EU VAT. Which list your service falls under decides the invoice.

Proving the customer is where they say

Non-EU businesses have no VIES number. Keep what shows the customer is a business established outside the EU: a company registration extract, a foreign tax identification number (a UK VAT number, a Swiss UID), the contract and the delivery address. The same evidence supports the "business, not consumer" distinction that decides between Articles 44 and 45.

Currency, language and payment

Invoice in the currency you agreed; if any VAT were due, its amount would have to be expressed in your national currency (Article 230), which for these supplies is moot. Invoice in a language the customer can read — English is usual — and make sure your own tax authority can still read it if asked (Article 248a). State the bank details fully, with IBAN and BIC or the local equivalent, and who bears transfer charges.

How EUFactura does it

For a business customer outside the EU, EUFactura suggests the export exemption on goods lines and "outside the scope" on service lines, cites Article 146 or 44 on the PDF and inserts the corresponding note. Services to a non-EU consumer are marked for review with the Article 59 question spelled out, because the app cannot know the service category.