How to Invoice Foreign Clients from Italy: A Complete Guide

How to issue an invoice to a foreign client

If you have a VAT number, you’re required to issue an invoice every time you complete a professional service—this applies whether your client is in Italy or abroad. However, invoicing foreign clients comes with a few specific differences and legal obligations.

Invoicing foreign clients: what changed with the new regulations?

Since July 2022, it has become mandatory to issue electronic invoices to foreign clients (those not fiscally established in Italy, both within the EU and outside the EU). The invoice must be created in XML format and submitted to the Sistema di Interscambio (SdI)—just like you would for domestic clients.

The Italian Revenue Agency’s ruling no. 293384/2021 introduced two key updates:

1. You must use the recipient code “XXXXXXX” when invoicing a foreign client.
   
   
2. You must use specific document types—TD17, TD18, or TD19—to report invoices received from foreign suppliers.
   
   

In this guide, we’ll walk you through how to properly create and send an invoice to a foreign client, whether or not they have a VAT number, and everything else you need to know to stay compliant.

Feeling overwhelmed? You're not alone. That’s why Xolo is here—to guide you step by step. We’ll help you adjust to these new invoicing requirements with ease and confidence.

Invoicing foreign clients: step-by-step

Until 2023, issuing a paper (analog) invoice to foreign clients was still permitted, as long as the data was reported via the Esterometro.

But from 2024, electronic invoicing through SdI is mandatory for all.

Here are the 3 key steps to issue an invoice to a foreign client (whether a company or an individual):

1. Complete the electronic invoice

Fill in all fields of the XML invoice. For foreign clients, pay special attention to:

• Recipient Code: must be “XXXXXXX”
  
  
• ZIP/Postal Code: use “00000”
  
  
• VAT Number Field: special rules apply (see below)
  
  

2. Send the XML invoice through SdI

Submit it via the Sistema di Interscambio to validate the invoice.

3. Send a copy to the client

Because foreign clients cannot access SdI, you must also send them the invoice in paper or PDF format. This step is not required for Italian clients.

Legal framework for invoicing foreign clients

The 2021 Budget Law (Art. 5, para 14-ter of Decree-Law 146/21) made e-invoicing mandatory in many cases that were previously exempt—such as foreign clients.

The Revenue Agency’s ruling 293384/2021 clarified that invoices to non-residents can be transmitted using full XML format, provided the <CodiceDestinatario> field is set to “XXXXXXX”.

What happened to the Esterometro?

The Esterometro was a quarterly electronic report used to communicate foreign transactions. It was required if you issued or received non-electronic invoices to/from non-resident entities.

Since 2024, electronic invoicing has become mandatory, and the Esterometro has been abolished.

💡 Tip: Using e-invoicing allows you to keep a single VAT register instead of maintaining separate records for paper and electronic invoices.

How to fill out an electronic invoice to a foreign client

When preparing the XML file, the following fields must be completed:

• Recipient Code: Use "XXXXXXX" for all foreign clients
  
  
• Country ID (“IdPaese”): Use the ISO 3166-1 alpha-2 code of the client’s country
  
  
• Postal Code (“CAP”): Always use "00000"
  
  
• Client VAT Number:
  
  
  • EU client: Use VAT number with country code prefix
    
    
  • Non-EU client: Use "OO99999999999" (double “O” + 11 nines)
    
    
  • Private client (no VAT): Use "0000000"
    
    
• Fiscal ID ("IdCodice") and Tax Code: Optional, only if the client has an Italian tax code
  
  
• "IdFiscaleIVA": Leave empty unless the client has an Italian tax code
  
  
• VAT Nature Code ("Natura IVA"):
  
  
  • N3.1 for exports
    
    
  • N3.2 for intra-EU supplies
    
    
  • N3.3 for San Marino
    
• Recipient PEC: Leave blank unless the client has a PEC address
  
  

A quick note on the Recipient Code field:

• XXXXXXX: for clients not established or identified in Italy
  
  
• 0000000: when the PEC is known or for clients from special tax areas like Campione d’Italia and Livigno
  
  

Sending the invoice

After filling out the XML, send it via SdI. But because foreign clients can’t access SdI, you must also send them:

• A PDF or paper copy
  
  
• A notification telling them the original invoice is filed on the Italian Revenue Agency's portal
  
  

Invoicing foreign clients without a VAT number

You must still issue an electronic invoice.

The only difference is in the VAT number field, where you’ll enter "0000000".

💬 Additional note on VAT descriptions:

• Intra-EU clients: add “reverse charge” to the invoice
  
  
• Non-EU clients: use “transaction not subject to VAT”
  
  

What about invoices received from foreign suppliers?

The new e-invoicing rules also affect how you handle foreign purchase invoices:

If the supplier is outside the EU:

• You’ll receive a D.A.U. (customs document)
  
  
• Submit this + the invoice to your tax advisor
  
  

If goods are imported from the EU:

• Submit a self-invoice with code TD18 via SdI
  
  
• Apply Italian VAT rates
  
  

If services are purchased from EU or non-EU:

• Submit a self-invoice with code TD17
  
  
• Again, include the relevant Italian VAT rate
  
  

⏱ You must send the invoice to SdI by the 15th of the month following the invoice date.

📌 Note: Foreign suppliers are not involved in this submission—it’s your responsibility as the Italian taxpayer.

Special cases: Campione d’Italia and Livigno

Although in Italy, these municipalities have special tax statuses and are treated like foreign jurisdictions.

Invoices to clients in these areas must:

• Be treated as cross-border transactions
  
  
• Include "0000000" as the Recipient Code
  
  
• Be submitted via SdI (like other foreign invoices)
  
  

Want to invoice foreign clients easily? Let Xolo help!

In this guide, we explained how to issue electronic invoices to foreign clients—with or without a VAT number—and how to handle exceptions like special tax areas.

Still unsure about XML formatting or VAT codes? Have international suppliers and don’t want to mess things up?

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