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Last updated: 6 November 2026

Selling consulting, B2B services and SaaS in Europe from outside the EU

You run a consultancy, an agency or a SaaS company outside the EU and you invoice clients in Europe. The EU sets one VAT scheme for sales to private individuals, but each country keeps its own withholding tax, digital services tax and e-invoicing rules. This guide compares 15 countries, with a link to the official source for each rule.

1
EU country to register in for VAT on consumer sales
Quarterly
Non-Union OSS return
2027
OSS opens to all private customers in the EU
15
Countries compared
Who this is for

Service and software companies with clients in Europe

Companies that invoice European businesses or consumers from a home country outside the EU.

Consultancies and agencies

B2B services sold across borders

Consulting, development, marketing and management firms outside the EU that invoice European companies for work done from home or on site.

SaaS and software

Subscriptions and licences

Software vendors selling subscriptions or licences to European businesses, and digital services to consumers.

EU suppliers

Companies selling to another EU country

Some withholding rules below reach EU suppliers too, such as the 19% Spain applies to EU and EEA residents.

UK clients

Anyone selling into the United Kingdom

The UK sits outside the EU system, with its own VAT registration, royalty withholding and e-invoicing timetable.

By country

What each of the 15 countries adds to the EU rules

National rules from official sources read on 6 November 2026. A tax treaty can lower them.

CountryWhat differs thereGuide
GermanyThe client withholds 15% plus the solidarity surcharge on fees for rights such as copyright and for know-how, not on ordinary consulting, development or marketing (§ 50a EStG).On request
FranceThe client withholds tax on any service supplied or used in France, consulting included, at the standard corporate tax rate, or 75% for a non-cooperative state, unless a treaty gives a better result (art. 182 B CGI).France guide
NetherlandsThe EU rules apply with no national specific found: the 25.8% royalty withholding only reaches payments to a related entity in a low-tax country or certain abusive arrangements (Belastingdienst).On request
SpainThe client withholds 24% on services used in Spain and on royalties, rights on computer programs included, or 19% for EU and EEA residents (arts. 13, 25 and 31 LIRNR).Spain guide
ItalyThe client withholds 30% on royalties, applied to 75% of the amount for copyright, so 22.5% (Agenzia delle Entrate), and its legal basis is repealed on 1 January 2027, with no replacement text found yet (art. 25 DPR 600/1973).On request
United Kingdom (outside the EU)A business not established in the UK registers for VAT whatever the value of its taxable supplies (HMRC), and the payer withholds 20% on intellectual property royalties paid abroad, or the treaty rate (ITA 2007 s. 906).On request
PolandSuppliers with no establishment in Poland stay out of KSeF e-invoicing (KSeF); a withholding on consulting and licences is reported by a public agency but not confirmed in the law (PARP).On request
IrelandThe EU rules apply with no national specific found: the 20% PSWT applies only when the payer is a designated public body (Revenue).On request
BelgiumThe EU rules apply with no confirmed national specific: Peppol e-invoicing excludes suppliers not established in Belgium (efacture.belgium.be), and a withholding on some services seen in secondary sources is unconfirmed.On request
SwedenThe EU rules apply with no national specific found, and the treatment of royalties paid abroad still needs a current official source (Skatteverket).On request
AustriaThe client withholds 20% on royalties and on consulting carried out in Austria (USP).On request
PortugalThe client withholds a final 25% on services performed or used in Portugal and on intellectual property income (art. 94 CIRC).On request
LatviaThe client withholds 20% on management and consulting fees paid to a non-resident, and on payments to a low-tax or non-cooperative jurisdiction, unless a treaty applies (State Revenue Service).Latvia guide
LithuaniaOfficial sources could not be read yet: the law and the tax authority's commentary were blocked (VMI).On request
EstoniaThe client withholds 10% on services rendered in Estonia and on royalties, but not on a service rendered remotely from abroad or on software bought for the client's own use (EMTA).On request

The France, Spain and Latvia guides go through each rule with its official text. Other countries are covered on a call.

VAT

VAT on services: what the EU sets for every country

One registration covers sales to private individuals in all EU countries.

A company with no establishment in the EU that supplies services to private individuals can register for the non-Union One-Stop Shop (OSS) in a single EU country and declare there, in a quarterly return, the VAT due in every other EU country (European Commission). From 1 January 2027, the scheme covers all services supplied to private individuals in the EU, with no condition on where the customer resides (Directive (EU) 2025/516).

Business customers

Reverse charge: confirm before you invoice

Where a service to an EU business is taxed, and whether the customer pays the VAT under the reverse charge, rests on Directive articles we have not re-read in the official text for this guide. Confirm the treatment with your client's tax office (Directive 2008/8/EC).

United Kingdom

A separate VAT registration

The UK applies neither the EU reverse charge nor the OSS. A business not established in the UK registers for UK VAT with no threshold, for example for digital services sold to consumers (HMRC, VATREG37050).

Withholding tax

Tax withheld by your client: what each country decides

Not harmonised in the EU. The client keeps part of your fee and pays it to its own tax office.

Withholding is left to each country, and it is the rule that most often changes what a supplier is paid. France, Spain and Portugal tax services supplied or used on their territory, Austria and Estonia services performed there, and Latvia management and consulting fees. Germany taxes licences and know-how, not ordinary consulting, and in Italy and the UK we found withholding on royalties but none on ordinary services.

The payer files and pays: in Germany on BZStOnline by the 10th of the month after the calendar quarter (BZSt), in France by the 15th of the month after the quarter on form 2494-SD, at the standard corporate tax rate given as 25% in the 2022 guidance (BOFiP), and in Austria by the 15th of the following month with form E 19 (USP).

Treaty relief

How a withholding is reduced or removed

Each country has its own procedure, and most of them run through your client's finance team.

We have not read the tax treaties for this guide. A treaty between your country and your client's can lower a national withholding or remove it, through the procedures below.

Germany

Exemption from the BZSt

The Federal Central Tax Office can reduce or waive the withholding, with a simplified procedure (Kontrollmeldeverfahren) for small cases. The request is made in German (§ 50c EStG, BZSt).

France

Treaties take priority

The withholding gives way to tax treaties, and a supplier from a treaty country can claim the more favourable treatment (BOFiP). The French payer applies it on your proof of residence.

Austria

A certificate handed to the payer

Your company gives the Austrian client a residence certificate on form ZS-QU2. Below EUR 10,000 a year per beneficiary, it can be omitted (USP).

Portugal

Proof before the due date

You prove your treaty entitlement to the Portuguese client before the withholding falls due, on a form certified by your own tax administration (Portal das Finanças).

United Kingdom

The payer applies the treaty rate

A UK payer of royalties can apply the treaty rate directly (s. 911 ITA 2007, SAIM9130).

Ireland

Refund on form IC11

A non-resident from a treaty country reclaims PSWT withheld by an Irish public body on form IC11 (Revenue).

Digital tax and e-invoicing

Digital services taxes and e-invoicing

Digital services taxes target large groups, and e-invoicing duties mostly stop at established businesses.

France (CIBS), Spain (Ley 4/2020) and Italy (Agenzia delle Entrate) charge 3% on some digital services, Austria 5% on online advertising (BMF) and the UK 2% (HMRC). Each applies only above EUR 750 million of worldwide revenue, or GBP 500 million in the UK, so a consultancy or SaaS company of ordinary size is outside them. Germany has none in force (Bundestag), and Poland's draft has not been adopted (gov.pl).

In the sources we read, none of the 15 countries makes a supplier with no establishment there issue e-invoices today. Germany (BMF), Poland (KSeF) and Belgium (efacture) exclude it expressly, Italy has the buyer send a TD17 self-invoice to the SDI (Agenzia delle Entrate), and Spain's VERI*FACTU reaches a non-resident only through a permanent establishment (AEAT).

France puts a foreign company without a permanent establishment under e-reporting through an approved platform, although the French buyer reports reverse-charged business sales and OSS consumer sales are left out. The reform starts on 1 September 2026 for large and mid-sized companies and 1 September 2027 for SMEs (impots.gouv.fr). Ireland follows from 1 November 2028 (Revenue) and the UK from 1 April 2029 (HMRC); neither source yet says whether non-established suppliers are covered.

Structure

Do you need an EU company?

Not to invoice European clients. It changes a few rates and brings duties of its own.

Home company

Enough to invoice European clients

The non-Union OSS covers VAT on services to private individuals without an EU entity. Withholding depends on your client's country and the treaty with yours, and a company based in another EU country is a non-resident there too.

A Latvian company has duties of its own. B2B e-invoicing becomes mandatory for companies registered in Latvia on 1 January 2028 (Ministry of Finance), and a Latvian payer withholds 20% on management or consulting fees paid to a non-resident (State Revenue Service).

If an EU company fits your plans, see our pages on forming an EU company as a non-resident and on a Latvian subsidiary for a foreign company.

How we help

What Balt Partners coordinates

One contact in Riga for the European side of your client contracts. Filings abroad go through a licensed local adviser.

Obligation map per client country

Withholding, VAT, e-invoicing and treaty documents for each country where you have clients, with your payers' deadlines in one calendar.

Treaty documents for your payers

The residence proof and treaty forms each payer asks for, such as form ZS-QU2 in Austria, prepared from Riga and sent before the payment falls due.

Requests to a foreign tax office

For an exemption or refund request to the German BZSt, we bring in a licensed adviser in Germany and coordinate the file.

A Latvian company if you need one

A Latvian SIA with its bank account and accounting set-up, when an EU company fits your plans.

FAQ

Questions from service and SaaS companies about Europe

No. A company based outside the EU can declare the VAT on services sold to private individuals in the EU through the non-Union One-Stop Shop, from a single EU country. An EU company would still be a non-resident in your clients' countries, so their withholding rules still apply.

It depends on the client's country and on what you sell. France, Spain and Portugal withhold on services supplied or used there, Austria and Estonia on services performed there, Latvia on management and consulting fees. Germany, Italy and the UK withhold on royalties and licence fees. A tax treaty can reduce or remove it.

It depends on the country. Estonia states that software bought for the client's own use is not a royalty. Spain counts rights on computer programs among royalties. In Germany, the view that SaaS used as intended carries no withholding still has to be confirmed with the Federal Central Tax Office.

In Austria, you give the payer a residence certificate on form ZS-QU2, not needed below EUR 10,000 a year. In Portugal, you prove your entitlement to the payer before the withholding falls due. A UK payer can apply the treaty rate directly. In Germany, you apply to the Federal Central Tax Office.

In the sources we read, none of the 15 countries requires it today from a supplier with no establishment there. Germany, Poland and Belgium exclude such suppliers expressly. France puts them under e-reporting through an approved platform instead, and in Italy the buyer sends a self-invoice to the SDI.

Yes. A business not established in the UK must register for UK VAT regardless of the value of its taxable supplies, so there is no threshold. The UK is outside the EU, so the EU One-Stop Shop does not cover these sales.

General information notice. This page summarises European and national rules as published in the official sources linked above, as of 6 November 2026. It is not tax or legal advice, and it does not cover every case. Tax treaties were not reviewed for this page and can change the rates shown. Balt Partners (FPFM SIA) is a Latvia-based firm: we map obligations and deadlines and coordinate the work, a licensed local adviser handles any filing abroad, and we do not give tax advice ourselves. Confirm any decision on your own contracts with a licensed adviser.

Invoicing clients in Europe?

Tell us which countries your clients are in and what you sell them. On a free call we map the withholding, VAT and e-invoicing rules for each country, then bring in a licensed adviser wherever a filing abroad is needed.