How remote consultants, fractional executives, specialist advisors and cross-border professional services firms bill UK and US corporate clients from Spain — VAT treatment, B2B service classification, invoicing, contracts and the structural choices that make cross-border consulting clean.
The remote-consultant-to-UK/US-client profile is the single most common expat business setup in Spain. A specialist (strategy, technology, finance, marketing, product) moves to Spain, continues serving the same pre-existing UK or US corporate clients from a new location, and needs a Spanish legal and tax structure that doesn't complicate the cross-border flow.
The good news: EU VAT place-of-supply rules make cross-border B2B consulting straightforward — foreign B2B services are out of scope for Spanish IVA. The bad news: Spanish gestores frequently misapply IVA, foreign clients sometimes try to treat the consultant as a contractor on home-country paperwork, and the personal-service-company traps from pre-IR35 UK / 1099 US contracting thinking don't translate to Spain without care.
This page focuses on the specifics of billing UK and US clients from Spain — invoice templates, contract clauses, VAT treatment, MSA/SOW patterns, and the SL vs autónomo decision for this specific client base.
Tax structuring, entity formation and sector-specific compliance for remote consultants, fractional executives, specialist advisors and cross-border professional services firms billing UK and US clients. Scoped at the outset with a written fee proposal.
Four commercial realities shape every Remote Consultants Serving UK/US Clients engagement in Spain.
Services to business clients outside Spain are generally taxed where the client is established (place-of-supply rule under Article 44 of EU VAT Directive). Result: Spanish consultant invoicing UK or US business client does not charge Spanish IVA.
The invoice shows zero IVA with a note — for EU clients, 'Inversión del sujeto pasivo' (reverse charge); for non-EU clients, 'Operación no sujeta al IVA español'. Modelo 303 reports the sale under 'no sujeto' / 'exento'.
Brexit didn't change the VAT treatment (UK clients still B2B outside Spain = out of scope). But ICX (intracommunitario) reporting on Modelo 349 no longer applies to UK-to-Spain flows.
UK reverse charge mechanism applies on the UK client side — they self-account for UK VAT. Our job is to ensure the Spanish invoice is correctly marked and documented; UK VAT is the client's side.
US client paying Spanish SL or autónomo: typically requests W-8BEN-E (for SL) or W-8BEN (for individual). This US tax form certifies foreign status to prevent US 30% withholding on service payments.
US clients don't charge Spanish consultant sales tax. State sales tax is applicable to physical-goods transactions and certain digital products, but not to services delivered from outside the US.
Remote consulting often runs on the client's paperwork (UK corporate MSA, US corporate MSA with local-counsel fallback). Governing-law clauses frequently default to client's home jurisdiction.
From the consultant's side, Spanish governing law is rarely practical — UK/US clients won't accept it. Better approach: English governing law (neutral, widely accepted) or client's governing law with Spanish tax-residency caveats drafted in.
Every engagement is scoped in writing with a named point of contact.
Full SL incorporation tuned to the sector's capital and governance profile.
IVA classification, corporate tax, Modelo filings, regime analysis.
Six-year 24% regime for qualifying founders and directors. Election window tight.
Digital Nomad, Self-Employment, Non-Lucrative — sector-appropriate routes.
Client MSAs, employment contracts, licensing agreements drafted and reviewed.
Quarterly and annual filings, handover to ongoing gestor, compliance calendar.
Spanish business banking setup for foreign founders, multi-currency where needed.
Employment contracts, Social Security, payroll, convenio compliance.
Six-step structured process — typically 4-6 weeks end to end.
60-minute call walking through your sector-specific situation, revenue profile, client base and residence status.
Written report with tax modelling and sector-specific recommendations before you engage.
NIE and residence registration where not already in place.
SL or autónomo registration with sector-appropriate IAE codes, licences and registrations.
OSS, ROI, CASP register, vivienda de uso turístico, etc. — specific to your activity.
Named gestor or in-house compliance partner, written compliance calendar, 12-month handover plan.
Illustrative client profiles across the sector.
The situation. UK CFO serving 4 UK Series A/B companies on fractional basis, £280k revenue, relocated.
How we'd handle it. SL + Beckham. Engagement letters templated with UK governing law, Spanish consultant tax-residency acknowledged. Invoices monthly to UK clients without VAT (reverse charge). Modelo 303 reports as 'no sujeto'. Fixed monthly compliance fee; founder took director's contract at £180k, retained remainder in SL.
The situation. American consultant serving US SaaS companies, $220k revenue, family of four.
How we'd handle it. SL + Beckham. W-8BEN-E filed with each US client at onboarding. US Form 5471 / 8938 coordination with US CPA. Invoices in USD; SL banking in USD plus EUR operational account.
The situation. Irish marketer on 6-month client engagements with UK agencies, €160k typical annual revenue.
How we'd handle it. Autónomo (below SL economics threshold). ROI for intracommunitario reporting to EU clients. Post-Brexit UK clients treated under out-of-scope B2B rules. Quarterly Modelo 303 and 130.
The situation. Canadian advisor serving mixed UK, US and Canadian clients, $300k revenue, solo.
How we'd handle it. SL + Beckham. Tri-jurisdictional invoicing structure documented. W-8BEN-E for US clients. ROI for UK/EU if applicable. Canadian non-resident status confirmed with CRA; NR73 filed.
Recurring errors specific to this sector — and how we prevent each.
Most common gestor error. Creates invoicing friction and Modelo 303 errors. UK/US B2B services are out of scope.
UK/US clients sometimes want to treat the Spanish consultant as 'contractor' on home-country employment paperwork. This creates tax-residency issues and employment reclassification risk.
PEM risk recurs. Clean structure: Spanish SL bills UK client directly.
US clients withhold 30% without valid W-8. Getting the form right at onboarding prevents withholding and paperwork pain.
Client MSAs can contain IP, governing-law or termination clauses that don't work from Spanish residency. We template-review client MSAs before signing.
Required in most UK/US MSAs. Spanish insurers underwrite; broker partners available.
Most remote consultants serving uk/us clients engagements start with a structure call where we understand the specifics — revenue, client geography, operational setup, existing entities, residency status. We don't start recommending entity types before we understand the numbers.
After the call we send a written recommendation with sector-specific tax modelling. You see actual numbers — SL vs autónomo, Beckham vs progressive, R&D credit where applicable, VAT treatment per client geography.
If you engage, we issue a written scope and fixed fee. Scope is specific to the sector — OSS registration for e-commerce, CASP registration for crypto, vivienda de uso turístico for property, image-rights licence for creators. Fee is fixed, in writing, before work begins.
We execute. You get a named point of contact. Weekly status during active phases. English-language throughout. Coordinated with your home-country advisor where applicable.
We hand over to an ongoing compliance provider — typically a gestor or small accounting firm — with a written 12-month compliance calendar. You don't lose visibility after setup, and we stay available for follow-up questions indefinitely.
Spain has thousands of gestores who can register an SL. What's scarce is sector-specific commercial capability — lawyers who understand how remote consultants serving uk/us clients actually operate, what goes wrong in your sector, and how to structure setup to prevent it.
Speak to a specialist who has structured remote consultants serving uk/us clients engagements before. Written scope. Fixed fee. Named point of contact.