Zero-Rated, Exempt and No-VAT Invoices: What the Invoice Must Say
An invoice can show 0% or no VAT for five different reasons, and each one needs different wording. This guide gives the exact rule for the EU and for the UK, quoted from the official text, and two worked examples. Sources retrieved .
Five reasons an invoice shows no VAT
Find your situation first. The wording that must appear on the invoice follows from it.
| Situation | What it means | What the invoice shows |
|---|---|---|
| Zero-rated (EU: exempt with the right to deduct) | The supply is taxable at 0%. The seller keeps the right to recover VAT on its own costs. | UK: the item at 0%, with no VAT payable. EU: 0% plus a reference to the exemption (Art. 226(11)); for intra-EU goods also the customer's VAT number. |
| Exempt | No VAT is due, and the seller normally cannot recover VAT on its costs. | EU: a reference to the exemption (Art. 226(11)). UK: the item shown clearly with no VAT payable. |
| Reverse charge | VAT is due, but the customer accounts for it instead of the seller. | The mention "Reverse charge" and the customer's VAT number. See the reverse charge calculator. |
| Outside the scope | The supply is not within the VAT system of that country at all, for example because it is made outside it. | No VAT line from that country. If the supply is taxable in another country, check that country's rules on who accounts for the VAT. |
| Seller not registered | The seller cannot charge VAT. | A normal invoice with no VAT, no VAT number and no "VAT invoice" title (UK: "Only VAT-registered businesses can issue VAT invoices", see below). |
HMRC defines "outside the scope" in VAT Notice 700: "Supplies are outside the scope of UK VAT if any of the following apply: made by someone who is not a taxable person; made outside the UK and the Isle of Man […]; not made in the course or furtherance of business." (VAT Notice 700, section 3)
EU: exempt with the right to deduct, and what the invoice must say
The EU VAT Directive does not use the word "zero-rated". It exempts the supply and, for certain exemptions, keeps the seller's right to deduct input VAT. Article 169(b) gives that right for "transactions which are exempt pursuant to Articles 136a, 138, 142 or 144, Articles 146 to 149 […]". Ireland's Revenue describes the same supplies as zero-rated: its zero-rate page lists "exports" and "intra-Community supplies of goods to VAT-registered persons in other European Union (EU) Member States" (Revenue.ie).
The two most common 0% supplies
- Intra-EU supply of goods (Article 138(1)). Exempt where the goods are dispatched to another Member State and "the taxable person or non-taxable legal person for whom the supply is made is identified for VAT purposes in a Member State other than that in which the dispatch or transport of the goods begins and has indicated this VAT identification number to the supplier". The customer's VAT number therefore has to be on the invoice (Article 226(4)), and you can check it in the EU's VIES service.
- Export of goods outside the EU (Article 146(1)(a)). Exempt: "the supply of goods dispatched or transported to a destination outside the Community by or on behalf of the vendor".
The exemption reference: Article 226(11)
"(11) in the case of an exemption, reference to the applicable provision of this Directive, or to the corresponding national provision, or any other reference indicating that the supply of goods or services is exempt;"
So "Exempt intra-Community supply, Article 138 Directive 2006/112/EC" satisfies the rule, and so does a reference to your own country's VAT law. Some tax authorities publish the wording they expect. Revenue.ie, for example, asks for "the customer's VAT number and a notation that this is an 'intra-Community supply of goods'" (Revenue.ie, information required on a VAT invoice).
Deadline for the invoice: Article 222
"For supplies of goods carried out in accordance with the conditions specified in Article 138 or for supplies of services for which VAT is payable by the customer pursuant to Article 196, an invoice shall be issued no later than on the fifteenth day of the month following that in which the chargeable event occurs."
Dated change. Directive (EU) 2025/516 (ViDA) amends Article 222: from 1 July 2028 the 15th-day rule also covers reverse charges under Article 194, and from 1 July 2030 the first paragraph becomes "an invoice shall be issued no later than 10 days following the chargeable event". These are the dates from which Member States must apply the new text through national law (Directive (EU) 2025/516).
UK: zero-rated vs exempt, and what HMRC requires
The UK is no longer bound by the EU Directive, so use HMRC's rules below for UK VAT, not Article 226.
"VAT is not payable on zero-rated supplies, and an invoice for a zero-rated supply will not constitute a VAT invoice […] Zero-rated supplies are treated as taxable supplies in all other respects, including the right of the person making the supply to recover the VAT on their own business expenditure […]"
"Some supplies are exempt from VAT, which means that no tax is payable — but, equally, the person making the supply cannot normally recover any of the VAT on their own expenses."
Do you need a VAT invoice at all?
Usually not for 0% UK sales. VAT Notice 700 (paragraph 16.2.1): "You do not, therefore, have to issue VAT invoices for zero-rated supplies." VAT Notice 700/21 (paragraph 4.6) lists "your invoice is only for exempt or zero-rated sales within the UK" among the cases where you do not always have to issue a VAT invoice to a registered person.
If a VAT invoice includes zero-rated or exempt items
"you must make sure that those items show clearly that there's no VAT payable and you must show a separate total for their values."
The March 2024 change: no reason needed
HMRC's change note on VAT Notice 700/21 dated 18 March 2024: "The reason for any zero rate or exemption has been removed from the list of details you must include on a VAT invoice." The one exception left in VAT Notice 700 (paragraph 16.3.1) is for goods sent from Northern Ireland to an EU customer: where that supply is zero-rated or exempt, "your invoice must also show the reason for that".
The 30-day rule
Where you do issue a VAT invoice, HMRC says you must "normally issue a VAT invoice within 30 days of the tax point arising" (VAT Notice 700, paragraph 16.2.3), unless an earlier invoice already created the tax point.
Not VAT-registered: an invoice without VAT
If you are not registered for VAT, your invoice simply has no VAT on it. It must not look like a VAT invoice.
- GOV.UK: "Only VAT-registered businesses can issue VAT invoices." (Charge, reclaim and record VAT)
- HMRC: "Only a VAT-registered person can issue a VAT invoice. There are financial penalties for the unauthorised issue of VAT invoices." (VAT Notice 700, paragraph 19.5.1)
- Waiting for your number? "You cannot include VAT on your invoices until you get your VAT registration number, but you can increase your prices to account for the VAT you'll need to pay to HMRC." (GOV.UK, Register for VAT)
- Threshold: you must register if "your total taxable turnover for the last 12 months goes over £90,000 (the VAT threshold)" (GOV.UK).
So leave out the VAT line, the VAT rate and any VAT number, and do not title the document "VAT invoice". The GOV.UK pages quoted here give no set wording for an unregistered seller; a plain line such as "Not registered for VAT" only tells the customer why no VAT appears.
EU small businesses using the small-enterprise exemption of Article 284 may issue a simplified invoice (Article 220a(1)(c)). The note each country expects is set in national law. France, for example, uses the mention "TVA non applicable, article 293 B du CGI" for its small-business scheme; the French VAT articles are being moved into a new code from 2027, so check the current reference on Légifrance.
Selling in a GST country (Australia, New Zealand, India and others) without being registered? The rules and a blank download are on our non-GST invoice template page.
Reverse charge: 0% on the invoice, VAT paid by the customer
A reverse-charge invoice also shows no VAT, but for a different reason: the customer accounts for it. In the EU the invoice must carry the mention "Reverse charge" (Article 226(11a)) and the customer's VAT number. The full wording for the EU and the UK, and the VAT the customer declares, are on our reverse charge calculator page.
Zero-rated invoice examples
Illustrations written for this guide. They are not output from our generator, and the names and numbers are placeholders.
Netherlands
VAT ID: NL[supplier number]
| Description | Qty | Unit price | VAT rate | Net |
|---|---|---|---|---|
| Machine parts | 10 | €120.00 | 0% | €1,200.00 |
| Taxable amount, exempt intra-Community supply | €1,200.00 | |||
| VAT | €0.00 | |||
| Total due | €1,200.00 | |||
Exempt intra-Community supply of goods: Article 138(1), Directive 2006/112/EC.
Why each line is there: customer VAT ID (Art. 226(4)); date of supply (Art. 226(7)); taxable amount per exemption (Art. 226(8)); exemption reference (Art. 226(11)); issued by the 15th of the month after the supply (Art. 222).
United Kingdom
VAT reg. no.: GB[seller number]
| Description | Qty | Unit price | VAT rate | Net |
|---|---|---|---|---|
| Standard-rated service (hours) | 5 | £80.00 | 20% | £400.00 |
| Zero-rated item — no VAT payable | 2 | £25.00 | 0% | £50.00 |
| Total at 20%, excluding VAT | £400.00 | |||
| Total zero-rated | £50.00 | |||
| VAT at 20% | £80.00 | |||
| Total due | £530.00 | |||
The zero-rated line shows clearly that no VAT is payable and has its own total, as VAT Notice 700 paragraph 16.5 requires. The 20% rate is the UK standard rate from our verified VAT rate data (GOV.UK / HMRC).
Mixed invoices: standard-rated and zero-rated lines together
You can put both on one invoice. The EU rule asks for the totals to be split: Article 226(8) requires "the taxable amount per rate or exemption, the unit price exclusive of VAT and any discounts or rebates if they are not included in the unit price". For UK VAT invoices HMRC asks for a separate total for the zero-rated and exempt items (paragraph 16.5, quoted above). Example 2 above shows the layout. You can also issue separate invoices; HMRC notes this "may be a useful way of keeping the necessary records for your business".
Australia: GST-free sales
Australia uses the term GST-free. The ATO: "You don't include GST in the price if your product or service is GST-free." A tax invoice must show enough information to determine, among other details, the "Extent to which each sale on the invoice is a taxable sale", and "A tax invoice that includes taxable and non-taxable items, must clearly show which items are taxable. Items are non-taxable if they are GST-free or input-taxed." (ATO, Tax invoices, last updated 18 September 2026; ATO, GST-free sales). Not registered for GST? See the non-GST invoice template.
Making a 0% or no-VAT invoice with our tools
What our VAT invoice generator prints today, stated plainly:
- It uses one VAT rate per invoice. With "Apply to Taxable Items Only" selected, each line has a "Taxable" tick box; a line you untick prints "(No VAT charged)" under its description.
- The VAT row stays on the PDF when the VAT total is 0, so a 0% invoice shows the VAT line at 0.00.
- The PDF does not print a VAT rate per line or a separate total for the zero-rated lines. Type the exemption reference and, for a UK VAT invoice with mixed lines, the zero-rated total into Notes.
- The reverse-charge note prints only when you tick the "Reverse charge" box.
- An optional "Supply Date / Tax Point" field prints only when you fill it.
If you prefer to lay the invoice out yourself, the blank VAT invoice template comes as an editable Word file and Excel file, where you can add a VAT-rate column and the exemption line.
The generator is free and unmetered for normal use; an anti-abuse cap of 20 PDFs per device per day (200 per IP) applies, and blank template file downloads are not metered. A one-line "Created free with myinvoicetemplate.com" credit is switched on by default and one free checkbox in the settings turns it off. Your draft is stored in your own browser on this device, so download and keep the PDF you need.
Zero-rated and no-VAT invoice FAQ
What is a zero-rated invoice?
It is an invoice for a supply taxed at 0%. HMRC's VAT Notice 700 says: "VAT is not payable on zero-rated supplies", and zero-rated supplies are "treated as taxable supplies in all other respects, including the right of the person making the supply to recover the VAT on their own business expenditure". In EU law the same idea appears as an exemption with the right to deduct, for example intra-EU supplies of goods (Article 138) and exports (Article 146) of Directive 2006/112/EC.
Is zero-rated the same as VAT exempt?
No. Both show no VAT on the invoice, but a zero-rated seller keeps the right to recover VAT on its own costs. For exempt supplies HMRC says "no tax is payable — but, equally, the person making the supply cannot normally recover any of the VAT on their own expenses" (VAT Notice 700, paragraph 3.6).
Do I have to issue a VAT invoice for zero-rated sales?
In the UK, not normally: VAT Notice 700 says "You do not, therefore, have to issue VAT invoices for zero-rated supplies", and Notice 700/21 lists "your invoice is only for exempt or zero-rated sales within the UK" among the cases where a VAT invoice is not always required. In the EU, an invoice is required for intra-EU supplies of goods under Article 138 (Article 220(1), point 3), and it must be issued by the 15th day of the following month (Article 222).
Can I send an invoice without VAT if I am not VAT registered?
Yes, and you must not add VAT to it. GOV.UK: "Only VAT-registered businesses can issue VAT invoices." HMRC adds that "There are financial penalties for the unauthorised issue of VAT invoices" (VAT Notice 700, paragraph 19.5.1). Issue a normal invoice with no VAT line and no VAT number.
What must an EU invoice say when no VAT is charged?
For an exempt supply, Article 226(11) of the VAT Directive requires a "reference to the applicable provision of this Directive, or to the corresponding national provision, or any other reference indicating that the supply of goods or services is exempt". For a reverse-charge supply, Article 226(11a) requires the mention "Reverse charge". For intra-EU supplies of goods, the customer's VAT number is also required (Article 226(4)).
Does a UK VAT invoice still have to give the reason for zero rating?
Not for UK sales in general. HMRC's change note on VAT Notice 700/21 (18 March 2024) says: "The reason for any zero rate or exemption has been removed from the list of details you must include on a VAT invoice." One exception remains in VAT Notice 700: for goods supplied from Northern Ireland to an EU customer that are zero-rated or exempt, "your invoice must also show the reason for that".
Is a reverse-charge invoice the same as a zero-rated invoice?
No. Under the reverse charge the customer, not the supplier, accounts for the VAT, and the invoice must carry the mention "Reverse charge" (Article 226(11a)). Our reverse charge calculator works out the VAT the customer declares and quotes the invoice wording in full.
Not tax advice. Whether a sale is zero-rated, exempt, reverse-charged or outside the scope depends on the facts and on the law of the country where it is taxed. The quotes above were checked against the linked official pages on 2026-09-25; confirm against them, or with an adviser, before you invoice.