Cross-border invoicing rules — which country's requirements apply, what goes on the invoice, and how to handle e-invoicing mandates. Use when the user asks about: cross-border invoice, invoicing foreign client, reverse charge invoice, multi-currency invoice, self-billing cross-border, credit note…
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Basic rule — invoicing follows rules of Member State where supply takes place
Place-of-supply country's rules applyVAT Directive 2006/112/EC, Art 219a(1)
Exception (a): Reverse charge — supplier not established in supply country — whose rules apply
Supplier's country sets the invoicing rulesVAT Directive 2006/112/EC, Art 219a(2)(a); Art 196
Exception (b): Supply outside the EU — whose rules apply
Supplier's country sets the invoicing rulesVAT Directive 2006/112/EC, Art 219a(2)(b)
Self-billing under reverse charge — whose rules apply
Place-of-supply country's rules apply (basic rule)VAT Directive 2006/112/EC, Art 219a; Art 224
Non-EU supplier making taxable supplies in EU — whose rules apply
Place-of-supply country's rules always apply (no exception)VAT Directive 2006/112/EC, Art 219a
VAT rate shown on reverse charge invoice
0% (N/A for reverse charge)VAT Directive 2006/112/EC, Art 226
VAT amount shown on reverse charge invoice
EUR 0.00 or blankVAT Directive 2006/112/EC, Art 226
Reverse charge notation — mandatory on intra-EU B2B reverse charge invoices
Must state 'Reverse charge' or equivalent in the relevant languageVAT Directive 2006/112/EC, Art 226; Art 196
Legislation reference on reverse charge invoice (English)
"Article 196, Council Directive 2006/112/EC" or national equivalentVAT Directive 2006/112/EC, Art 226
Reverse charge notation — German
"Steuerschuldnerschaft des Leistungsempfängers — § 13b UStG"§ 13b UStG (Umsatzsteuergesetz)
Reverse charge notation — French
"Autoliquidation — Article 196, Directive 2006/112/CE"VAT Directive 2006/112/EC, Art 196
Reverse charge notation — Italian
"Inversione contabile — Art. 196, Direttiva 2006/112/CE"VAT Directive 2006/112/EC, Art 196
Reverse charge notation — Spanish
"Inversión del sujeto pasivo — Artículo 196, Directiva 2006/112/CE"VAT Directive 2006/112/EC, Art 196
Reverse charge notation — Dutch
"BTW verlegd — Artikel 196, Richtlijn 2006/112/EG"VAT Directive 2006/112/EC, Art 196
Reverse charge notation — Portuguese
"Autoliquidação — Artigo 196.º, Diretiva 2006/112/CE"VAT Directive 2006/112/EC, Art 196
EU default deadline for issuing invoices
By the 15th of the month following the month in which the supply took placeVAT Directive 2006/112/EC, Art 222
Germany — invoice issuance deadline
No later than 6 months after supply§ 14 UStG (Umsatzsteuergesetz)
France — invoice issuance deadline
By the 15th of the following monthVAT Directive 2006/112/EC, Art 222; Code Général des Impôts
Italy — invoice issuance deadline (standard)
By the 15th of the following monthVAT Directive 2006/112/EC, Art 222; DPR 633/1972 (Italian VAT Decree)
Italy — invoice issuance deadline (immediate invoices)
By the 12th of the following monthDPR 633/1972 (Italian VAT Decree)
Spain — invoice issuance deadline
By the 15th of the following monthVAT Directive 2006/112/EC, Art 222; Real Decreto 1619/2012 (Spanish Invoicing Regulations)
Netherlands — invoice issuance deadline
Before the 15th of the following monthVAT Directive 2006/112/EC, Art 222; Wet op de omzetbelasting 1968
Belgium — invoice issuance deadline
By the 15th of the following monthVAT Directive 2006/112/EC, Art 222; Code TVA belge
EU — currency for VAT amount on invoice
Currency of the Member State where the supply takes place; foreign currency invoices converted using ECB rate or national customs rateVAT Directive 2006/112/EC, Art 230
EU — exchange rate date for VAT currency conversion
Rate on the date of the chargeable event (typically date of supply); some member states accept date of invoiceVAT Directive 2006/112/EC, Art 230
UK — exchange rate accepted for VAT conversion
Rate at the date of supply; HMRC, ECB, or reputable financial source acceptedHMRC VAT Notice 700
US — exchange rate for sales tax on foreign currency invoices
Exchange rate on the date of transactionState sales tax regulations (varies by state)
Union OSS / Non-Union OSS — required return currency
EUR; if MSI does not use EUR, convert at ECB rate on the last day of the quarterCouncil Regulation (EU) 904/2010; VAT Directive 2006/112/EC (OSS provisions)
IOSS — required return currency
EURVAT Directive 2006/112/EC (IOSS provisions)
Domestic VAT return — required currency
Local currency of the member stateVAT Directive 2006/112/EC
Self-billing — prior agreement requirement
Written agreement required between supplier and customer for customer to issue invoices on supplier's behalfVAT Directive 2006/112/EC, Art 224
OSS — correction of prior quarter returns
Corrections to previous OSS quarters made on the next regular quarterly return (not by amending the original)VAT Directive 2006/112/EC (OSS provisions); Commission Implementing Regulation (EU) 282/2011
Credit note — exchange rate to use when rate has changed since original invoice
Use the rate at the date of the credit note for the adjustmentVAT Directive 2006/112/EC, Art 230
Italy SDI — mandate start date for domestic invoices
2019 (domestic)Legislative Decree No. 127/2015 (Italy); DL 79/2019
Italy SDI — mandate start date for cross-border invoices
July 2022Legislative Decree No. 127/2015 (Italy); Law Decree 36/2022
Italy SDI — Esterometro abolition year
2022 (replaced by SDI reporting)Law Decree 36/2022 (Italy)
Italy SDI — format
FatturaPA XML formatProvvedimento Agenzia delle Entrate (Italy); Legislative Decree No. 127/2015
Italy SDI — foreign supplier selling to Italy obligation
Not required to use SDI (unless established in Italy). Italian buyer self-assesses VAT and reports via SDI using document types TD17–TD19.Legislative Decree No. 127/2015 (Italy); Provvedimento Agenzia delle Entrate
Italy SDI — technical specs version effective date
SDI technical specs v1.9.1 effective May 15, 2026Agenzia delle Entrate SDI technical specification v1.9.1
Italy SDI — new validation check introduced in v1.9.1
Error 00327 for VAT GroupsAgenzia delle Entrate SDI technical specification v1.9.1
India IRN — e-invoicing turnover threshold
₹5 crore (since August 2023)CGST Rules 2017, Rule 48(4); CBIC Notification No. 10/2023 (Central Tax)
India IRN — export invoice requirement
Must be reported to IRP and receive an IRN; tax invoice must include QR codeCGST Rules 2017, Rule 48; CGST Act 2017
India IRN — export supply type code (with IGST payment)
EXPWP (export with payment of IGST)CGST Rules 2017, Rule 48; IRP schema
India IRN — export supply type code (without IGST payment)
EXPWOP (export without payment — under LUT)CGST Rules 2017, Rule 48; IRP schema
Mexico CFDI — required format
CFDI 4.0Resolución Miscelánea Fiscal (SAT); Código Fiscal de la Federación, Art 29
Mexico CFDI — RFC for foreign recipients
XEXX010101000Resolución Miscelánea Fiscal (SAT); Código Fiscal de la Federación
Mexico CFDI — penalty for non-compliance
5%–10% of invoice amountCódigo Fiscal de la Federación (Mexico)
Mexico CFDI — penalty for fraudulent CFDI
Criminal liability (prison); SAT has expedited powers to suspend digital certificatesCódigo Fiscal de la Federación (Mexico)
ViDA — deemed supplier rules for platforms (accommodation, transport)
Effective July 2028ViDA Directive (EU) — VAT in the Digital Age
ViDA — mandatory e-invoicing for intra-EU B2B transactions
Mandatory from July 2030; EN16931 standard; digital reporting requirementsViDA Directive (EU) — VAT in the Digital Age
ViDA — Italy SdI derogation expiry / full ViDA alignment deadline
2035ViDA Directive (EU) — VAT in the Digital Age
Germany — invoice retention period
10 years; electronic invoices must remain in electronic form§ 14b UStG (Umsatzsteuergesetz)
France — invoice retention period
10 years; electronic invoices in original electronic formatArt L102B, Livre des Procédures Fiscales
Italy — invoice retention period
10 years; stored via approved electronic conservation ("conservazione sostitutiva")Art 2220, Codice Civile (Italy)
Spain — invoice retention period
4 years + additional years if open auditArt 29.2, Ley General Tributaria (Spain)
Netherlands — invoice retention period
7 yearsArt 52 AWR (Algemene wet inzake rijksbelastingen)
UK — invoice retention period
6 yearsVAT Regulations 1995 (UK)
Belgium — invoice retention period
7 yearsArt 60 Code TVA (Belgium)
US — invoice retention period (sales tax)
Varies by state — typically 3–7 years; 7 years recommendedState sales tax regulations (varies by state)
EU — cross-border storage location rule
May store outside the member state, but must provide online access to the tax authority on requestVAT Directive 2006/112/EC, Art 247
EU credit note — legislative basis
Any document or message that amends and refers specifically and unambiguously to the initial invoiceVAT Directive 2006/112/EC, Art 219
Intra-EU reverse charge — customer VAT number verification requirement
Customer VAT number must be verified via VIESVAT Directive 2006/112/EC, Art 226; Council Regulation (EU) 904/2010 (VIES)
Consequence of missing reverse charge notation
Invoice legally deficient; customer's tax authority may deny input VAT deductionVAT Directive 2006/112/EC, Art 226
Consequence of invalid customer VAT number — supplier liability
If number is invalid, reverse charge does not apply; supplier liable for domestic VATVAT Directive 2006/112/EC, Art 196; Council Regulation (EU) 904/2010
Disclaimer: This skill provides general guidance on cross-border invoicing rules. Invoice requirements are jurisdiction-specific and evolving rapidly due to e-invoicing mandates. Consult a qualified advisor before relying on this information for compliance.
Skill Metadata
| Field | Value |
|---|---|
| Jurisdiction | Multi-jurisdiction (EU, UK, US, India, Italy, Mexico, and general principles) |
| Primary Legislation | EU: VAT Directive 2006/112/EC, Articles 217–240; Art 219a (invoicing rules applicable); ViDA Directive (phased 2028–2035) |
| Scope | Invoice format, content, currency, e-invoicing, and archiving requirements for cross-border transactions |
| Contributor | OpenAccountants |
| Validation Date | May 2026 |
| Skill Version | 1.0 |
| Cross-references | eu-reverse-charge.md, vat-place-of-supply-master.md, eu-oss-digital.md, country-specific e-invoicing skills |
The Exceptions — Article 219a(2) (Article 219a(2))
| Exception | When It Applies | Whose Rules |
|---|---|---|
| (a) Reverse charge — supplier not established in supply country | B2B intra-EU services where customer self-assesses VAT (Art 196) | Supplier's country sets the invoicing rules |
| (b) Supply outside the EU | Services deemed supplied outside the EU | Supplier's country sets the invoicing rules |
| Self-billing under reverse charge | Customer issues the invoice on behalf of the supplier | Place-of-supply country's rules apply (basic rule) |
| Non-EU supplier making taxable supplies in EU | Non-EU seller with EU-taxable transactions | Place-of-supply country's rules always apply (no exception) |
Practical Impact
| Scenario | Whose Invoicing Rules? |
|---|---|
| German consultant invoices French company (B2B reverse charge) | Germany (supplier's rules — exception (a)) |
| French company sells goods domestically | France (place of supply = France) |
| Italian company invoices US client for consulting | Italy (supply outside EU — exception (b)) |
| US company sells SaaS to French consumer via non-Union OSS | France (place of supply = France; non-EU supplier — no exception) |
| Dutch company issues self-billing invoice for services received from Malta under reverse charge | Netherlands (self-billing under reverse charge = basic rule) |
Mandatory Invoice Content for Intra-EU B2B Under Reverse Charge (VAT Directive Art 226)
| Element | Requirement |
|---|---|
| Invoice number | Sequential, unique |
| Date of issue | Date the invoice is created |
| Date of supply | Date the service was performed or goods delivered (if different from issue date) |
| Supplier identification | Full name, address, VAT identification number |
| Customer identification | Full name, address, VAT identification number (verified via VIES) |
| Description | Nature and quantity of goods supplied or extent and nature of services |
| Taxable amount | Net amount in the agreed currency |
| VAT rate | N/A for reverse charge (0%) |
| VAT amount | EUR 0.00 or blank |
| Reverse charge notation | Mandatory. Must state "Reverse charge" or equivalent in the relevant language |
| Reference to legislation | "Article 196, Council Directive 2006/112/EC" or national equivalent |
Reverse Charge Notation by Country
| Country | Notation |
|---|---|
| English | "Reverse charge — Article 196, Council Directive 2006/112/EC" |
| German | "Steuerschuldnerschaft des Leistungsempfängers — § 13b UStG" |
| French | "Autoliquidation — Article 196, Directive 2006/112/CE" |
| Italian | "Inversione contabile — Art. 196, Direttiva 2006/112/CE" |
| Spanish | "Inversión del sujeto pasivo — Artículo 196, Directiva 2006/112/CE" |
| Dutch | "BTW verlegd — Artikel 196, Richtlijn 2006/112/EG" |
| Portuguese | "Autoliquidação — Artigo 196.º, Diretiva 2006/112/CE" |
Time Limits for Issuing Invoices by Country
| Country | Deadline |
|---|---|
| Germany | Immediately, but no later than 6 months after supply (§14 UStG) |
| France | By the 15th of the following month |
| Italy | By the 15th of the following month (12th for immediate invoices) |
| Spain | By the 15th of the following month |
| Netherlands | Before the 15th of the following month |
| Belgium | By the 15th of the following month |
What Changes on the Invoice When Reverse Charge Applies
| Normal Invoice | Reverse Charge Invoice |
|---|---|
| Shows VAT rate (e.g., 19%) | Shows 0% or no VAT line |
| Shows VAT amount (e.g., EUR 950) | Shows EUR 0.00 or omits VAT amount |
| No special notation needed | Must include reverse charge notation |
| Only supplier's VAT number required | Both supplier and customer VAT numbers required |
| Customer pays gross amount | Customer pays net amount only |
Common Mistakes
| Mistake | Consequence |
|---|---|
| Supplier charges domestic VAT instead of reverse charge | Customer pays VAT they shouldn't. Double taxation risk if customer also self-assesses. Supplier must issue credit note. |
| Missing reverse charge notation | Invoice does not meet legal requirements. Customer's tax authority may deny input VAT deduction. |
| Customer's VAT number not on invoice | Cannot prove B2B nature. Tax authority may reclassify as B2C. |
| Supplier doesn't verify VAT number via VIES | If number is invalid, reverse charge does not apply. Supplier liable for domestic VAT. |
Which Currency for VAT Calculation? (VAT Directive Art 230)
| Jurisdiction | Rule |
|---|---|
| EU (VAT Directive Art 230) | VAT amount must be expressed in the currency of the Member State where the supply takes place. If invoiced in a foreign currency, convert using ECB rate or national customs rate. |
| ECB exchange rate | Use the rate on the date of the chargeable event (typically date of supply). Alternatively, some member states accept the rate on the date of invoice. |
| UK | HMRC accepts the rate at the date of supply. Use HMRC, ECB, or a reputable financial source. |
| US | No VAT — but for sales tax, use the exchange rate on the date of transaction. |
Practical Guidance for Multi-Currency Invoices
| Element | Best Practice |
|---|---|
| Invoice currency | Invoice in whatever currency the contract specifies (USD, GBP, EUR, etc.) |
| VAT amount | Convert to the local currency using the applicable exchange rate |
| Exchange rate source | ECB daily rate (EU), HMRC rate (UK), Federal Reserve rate (US) |
| Document the rate | State the exchange rate and source on the invoice or in your records |
| Consistency | Use the same exchange rate source consistently — switching sources can trigger audit queries |
OSS Returns and Currency
| Scheme | Currency Required |
|---|---|
| Union OSS / Non-Union OSS | EUR. If your MSI doesn't use EUR, convert at ECB rate on the last day of the quarter. |
| IOSS | EUR |
| Domestic VAT return | Local currency of the member state |
Conditions for Self-Billing
| Condition | Requirement |
|---|---|
| Prior agreement | Supplier and customer must have a written agreement that the customer will issue invoices on the supplier's behalf |
| Acceptance procedure | There must be a mechanism for the supplier to accept or reject each invoice |
| Invoicing rules | Follow the rules of the place-of-supply country (Art 219a basic rule applies to self-billing under reverse charge) |
Cross-Border Self-Billing
| Scenario | Whose Rules? |
|---|---|
| Dutch customer self-bills for services received from Italian supplier (reverse charge) | Netherlands (place of supply = Netherlands; self-billing under reverse charge follows basic rule, not supplier's rules) |
| US customer self-bills for services from German supplier | Germany (supply outside EU — exception (b) — supplier's rules) |
When to Issue a Credit Note
| Trigger | Action |
|---|---|
| Price reduction after supply | Issue credit note referencing original invoice |
| Return of goods | Issue credit note for returned items |
| Invoice error (wrong amount, wrong VAT) | Issue credit note + new corrected invoice |
| Retrospective discount (e.g., volume rebate) | Issue credit note at end of period |
Credit Note Requirements (EU) (VAT Directive Art 219)
| Element | Requirement |
|---|---|
| Format | "Any document or message that amends and refers specifically and unambiguously to the initial invoice" |
| Reference | Must cite the original invoice number and date |
| Content | Corrected amounts, including VAT adjustments |
| Reverse charge credit notes | Same reverse charge notation as original. Customer must reverse their self-assessment. |
Cross-Border Credit Note Complications
| Issue | Guidance |
|---|---|
| Different reporting periods | Credit note may fall in a different quarter from the original invoice. Report in the period the credit note is issued. |
| OSS corrections | Corrections to previous OSS quarters are made on the next regular quarterly return (not by amending the original). |
| Currency differences | If exchange rate has changed since the original invoice, use the rate at the date of the credit note for the adjustment. |
| Customer in a different country has already filed | Customer must adjust their VAT return in the period the credit note is received. |
Italy — SDI (Sistema di Interscambio)
| Element | Rule |
|---|---|
| Mandate | All Italian-established businesses must issue e-invoices via SDI (since 2019 for domestic; since July 2022 for cross-border) |
| Cross-border sales | Italian businesses must submit an XML e-invoice to SDI even when invoicing foreign customers. The Esterometro was abolished in 2022; replaced by SDI reporting. |
| Format | FatturaPA XML format. SDI validates the invoice before forwarding. |
| Foreign supplier selling to Italy | Not required to use SDI (unless established in Italy). The Italian buyer self-assesses VAT and reports via SDI using document types TD17–TD19. |
| 2026 update | SDI technical specs v1.9.1 effective May 15, 2026. New validation checks (error 00327 for VAT Groups). |
| ViDA impact | EU ViDA Directive will require alignment with EN16931 standard. Italy's SdI clearance model may need adaptation by 2035. |
India — IRN (Invoice Reference Number)
| Element | Rule |
|---|---|
| Mandate | E-invoicing mandatory for businesses with turnover ≥₹5 crore (since August 2023) |
| Cross-border exports | Export invoices must also be reported to the Invoice Registration Portal (IRP) and receive an IRN. Tax invoice must include QR code. |
| Format | JSON schema submitted to IRP. IRP validates, generates IRN + QR code, digitally signs. |
| Foreign supplier to India | Not required to use IRP. Indian buyer handles GST under reverse charge. |
| Key fields for exports | Supply type = "EXPWP" (export with payment of IGST) or "EXPWOP" (export without payment — under LUT). Shipping bill details required. |
Mexico — CFDI (Comprobante Fiscal Digital por Internet)
| Element | Rule |
|---|---|
| Mandate | All invoices by Mexican-established entities must be CFDI 4.0 format, issued through a PAC (Authorized Certification Provider) with real-time SAT clearance |
| Cross-border sales | Mexican entity invoicing a foreign client not registered with SAT must still generate a CFDI through the clearance process. Use RFC "XEXX010101000" for foreign recipients. |
| Foreign supplier to Mexico | Not required to issue CFDI. Mexican buyer may need to issue a CFDI for the foreign payment (complemento de pagos). |
| Penalties | Non-compliance: 5%–10% of invoice amount. Fraudulent CFDI: criminal liability (prison). SAT has expedited powers to suspend digital certificates. |
| Complements | Specific transaction types require CFDI complements: payroll (nómina), foreign trade (comercio exterior), payments (pagos), tax withholdings (retenciones). |
EU ViDA (VAT in the Digital Age) — Phased Rollout
| Date | Change |
|---|---|
| July 2028 | Deemed supplier rules for platforms (accommodation, transport). Strengthened reverse charge. |
| July 2030 | Mandatory e-invoicing for intra-EU B2B transactions. Digital reporting requirements. E-invoicing becomes default form. EN16931 standard. |
| 2035 | Italy's SdI derogation expires. Full ViDA alignment required. |
Whose Retention Rules Apply? (VAT Directive Articles 244–248)
| Rule | Detail |
|---|---|
| General principle | Each member state sets its own retention period and format requirements for invoices related to supplies made in its territory. |
| Supplier | Must retain copies of issued invoices per the rules of the member state where they are established. |
| Customer | Must retain received invoices per the rules of the member state where they are established. |
| Cross-border | Both parties retain under their own country's rules. If these differ, the stricter rule is the safest approach. |
Retention Periods by Country
| Country | Retention Period | Format |
|---|---|---|
| Germany | 10 years (§14b UStG) | Original format (paper or electronic). Electronic invoices must remain in electronic form. |
| France | 10 years (Art L102B, Livre des Procédures Fiscales) | Electronic invoices in original electronic format |
| Italy | 10 years (Art 2220, Codice Civile) | Must be stored via approved electronic conservation ("conservazione sostitutiva") |
| Spain | 4 years (Art 29.2, Ley General Tributaria) + additional years if open audit | Original format |
| Netherlands | 7 years (Art 52 AWR) | Original format |
| UK | 6 years (VAT Regulations 1995) | Original format |
| Belgium | 7 years (Art 60 Code TVA) | Original format |
| US | Varies by state — typically 3–7 years for sales tax; 7 years recommended | Any legible format |
Key Principles for Cross-Border Archiving
| Principle | Guidance |
|---|---|
| Authenticity of origin | You must be able to prove who issued the invoice (digital signature, EDI, internal controls) |
| Integrity of content | The invoice content must not have been altered after issue |
| Legibility | The invoice must be readable (human or machine) throughout the retention period |
| Storage location | EU: May store outside the member state, but must provide online access to the tax authority on request (Art 247) |
| Language | Some countries (France, Germany, Italy) may require invoices to be in the local language or translatable on request during audit |
Input: German consultant invoices French company (valid FR VAT) EUR 5,000 for advisory services. Expected: Invoice follows German rules (Art 219a exception (a)). No VAT. Notation: "Steuerschuldnerschaft des Leistungsempfängers" or "Reverse charge — Art 196 Directive 2006/112/EC." Both VAT numbers on invoice.
Input: Italian software company invoices US client EUR 20,000 for development services. Expected: Supply outside EU (Art 219a exception (b)). Italian invoicing rules apply. Must submit XML to SDI (post-July 2022). No VAT (out of scope). Retain for 10 years in electronic conservation.
Input: Maltese company invoices a Japanese client USD 10,000 for consulting. Place of supply = Japan. Expected: Maltese invoicing rules (exception (b)). Invoice in USD is fine. If VAT were applicable, convert to EUR at ECB rate on date of supply. Retain for Maltese period.
Input: German e-commerce seller issued an OSS invoice to an Italian consumer in Q1. In Q2, the consumer returns the goods. Expected: Issue credit note referencing original invoice. Report the correction on the Q2 OSS return under Italy, not by amending Q1.
Input: Mexican SaaS company invoices a Colombian client $5,000/month for software. Expected: Must issue CFDI 4.0 via PAC with real-time clearance. Use RFC "XEXX010101000" for foreign recipient. Complemento de comercio exterior may be required.
This skill and its outputs are provided for informational and computational purposes only and do not constitute tax, legal, or financial advice. Open Accountants and its contributors accept no liability for any errors, omissions, or outcomes arising from the use of this skill. Invoicing requirements are evolving rapidly due to e-invoicing mandates worldwide. Always verify current rules with official sources and a qualified advisor.
Data reflects 2025–2026 rules. OpenAccountants — open-source accounting skills for AI — info@openaccountants.com
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