Disclaimer: This article provides general information about Portuguese tax and compliance rules and does not constitute tax, legal or accounting advice. Individual circumstances vary and rules change. Always consult a qualified Portuguese accountant or contabilista certificado before making decisions based on this information.
Ask in any Portuguese freelancing group whether you have to charge IVA, and you will get two numbers back with equal confidence. Some people say €15,000. Others insist it is €25,000, and that the first group is working from out-of-date information.
At Remote Work Europe we are very used to every social media contributor being an accountant and tax lawyer in their spare time, and it’s interesting sometimes to track how these misconceptions come about and then get propagated. In this case the misunderstanding is easy to identify.
Both numbers are real. Both are current. They govern completely different things, and the people quoting them are usually answering different questions without realising it.
Here is what each one actually does.
In short: €15,000 is the VAT exemption threshold under Article 53 of the CIVA, and it applies if you have ongoing freelance activity. €25,000 was a registration threshold for one-off jobs – and it was abolished on 1 July 2025. An ato isolado now requires no start-of-activity declaration at any value, and it still never qualifies for the Article 53 exemption.
The short answer
| Figure | What it actually governs | Where it comes from |
|---|---|---|
| €15,000 | The turnover ceiling for the VAT exemption regime, if you have ongoing freelance activity | Article 53 of the CIVA |
| €25,000 | formerly Article 31.º n.º 3 CIVA | |
| €18,750 | Cross this mid-year and you leave the exemption immediately, not next January | Article 58 of the CIVA |
If you have an already opened activity and invoice clients regularly, your number is €15,000. The €25,000 figure never applied to you – and it no longer applies to anyone.
What is the €15,000 VAT threshold in Portugal?
Article 53 exempts you from charging IVA if you are established in Portugal, you do not carry out exports or related activities, and your national turnover in the previous calendar year did not exceed €15,000.
Two things people routinely get wrong about it.
It looks backwards, not at today. The test is what you invoiced last calendar year. Someone who billed €14,000 in 2025 is exempt through 2026 even if this year turns out much better – subject to the €18,750 rule below.
It is a threshold you cross, not an allowance you spend. The exemption is not “your first €15,000 is VAT-free”. Once you are out of the regime, IVA applies to your invoices from the relevant date onwards, not just to the amount above the line.
What if I have just opened activity?
There is no previous year to look at, so you estimate your turnover for the current calendar year yourself and put that figure on your start-of-activity declaration.
⚠️ If you start partway through the year, you estimate only what you expect to earn between your start date and 31 December. You do not scale it up to a full year.
This changed, and it is the single most common piece of out-of-date advice still circulating. Under the old rules a part-year figure was converted into an annual equivalent, so starting in July expecting €10,000 would have counted as €20,000 and put you outside the exemption. That annualisation was removed. The tax authority’s own worked example is explicit: start in July expecting €10,000 by year end, and you are inside the exemption for that year.
If you then actually earn €12,000, you stay in it the following year. If you actually earn €16,000, you leave it — file a declaração de alterações within 15 working days of year end, and the normal regime applies from 1 January.
⚠️ A second thing changed at the same time. Under the older wording your estimate had to be confirmed by the tax authority. Under the current text it is simply the amount estimated by the taxable person. If a page tells you AT must approve your figure first, or shows you a formula for annualising it, that page is describing rules that no longer apply.
One useful detail: if you did an ato isolado earlier in the same year, its value does not count towards that start-of-activity estimate.
What happened to the €25,000 ato isolado limit?
An ato isolado is a genuinely one-off piece of work – a single taxable transaction in a calendar year, not the start of a regular activity. You issue a one-off invoice for it without opening activity at all.
Until 1 July 2025, €25,000 was the point at which that stopped being informal. Below it you could issue the invoice without filing a start-of-activity declaration; above it you had to file one first, flagged as an ato isolado.
🚩 That threshold is gone. Decreto-Lei n.º 49/2025 of 27 March rewrote Article 31.º n.º 3 of the CIVA with effect from 1 July 2025. It now reads, in full:
“Não há lugar à entrega da declaração referida no n.º 1 quando se trate de pessoas sujeitas a IVA pela prática de uma só operação tributável nos termos da alínea a) do n.º 1 do artigo 2.º”
No value qualifier. The old text ended with an exception for anything exceeding the limit in Article 29.º n.º 1 e) and f) – and Article 29.º n.º 1 e) now reads “(Revogado.)”. That exception was what carried the €25,000.
So an ato isolado today requires no start-of-activity declaration at any value. What replaced the registration duty is an invoicing one: under Article 4.º-A n.º 2 of Decreto-Lei n.º 28/2019, also added by DL 49/2025, anyone carrying out a single taxable operation must issue the invoice through the tax authority’s own invoicing applications.
⚠️ A footnote on where the figure lived. The €25,000 is often attributed to Article 29. The obligation always sat in Article 31.º n.º 3, which merely cross-referred to Article 29 for the number. There is still a €25,000 in Article 29.º n.º 1 f) – but it governs the annual mapa recapitulativo of suppliers, which is a different obligation entirely and has nothing to do with one-off jobs.
Does an ato isolado get the VAT exemption?
This is the part that turns a wrong number into a real bill.
An ato isolado does not qualify for the Article 53 exemption at all – regardless of the amount. The tax authority states this explicitly, and Article 53 itself excludes anyone carrying out a single taxable operation.
The consequence is counter-intuitive enough that it is worth spelling out:
- Bill €14,000 across the year as an ongoing freelancer under Article 53 → no IVA charged
- Do one job for €500 as an ato isolado → IVA is charged, at whatever rate the activity attracts
The small one-off is taxed and the much larger ongoing income is not. Someone who has heard “the threshold is €25,000” and assumes their €800 one-off is comfortably under it will not charge IVA, will not remit it, and will be wrong.
(Objective exemptions under Article 9 – certain medical activities, for instance – can still apply on their own terms. That is a different exemption from Article 53.)
One further wrinkle worth knowing: the value of an ato isolado does count towards your turnover for the year in which the tax becomes due. Ofício Circulado n.º 25094, of 5 December 2025, is explicit that it “deve ser integrado no cálculo do volume de negócios do ano em que ocorre a respetiva exigibilidade”. The carve-out is narrower than it is usually described: it applies only to an ato isolado carried out before you open activity, and only for working out your initial enquadramento.
What happens if I cross €15,000 mid-year? The €18,750 rule
Most explanations stop at €15,000 and leave you thinking you are safe until January. You are not.
If your turnover during the current calendar year exceeds the threshold by more than 25% – that is €18,750 – you leave the exemption from that moment, not at year end. You have 15 working days from crossing it to file a declaração de alterações.
The two exits work differently, and the difference matters:
| What happened | When you start charging IVA | Deadline to declare |
|---|---|---|
| Exceeded €15,000 in the previous calendar year | 1 January of the following year | 15 working days from year end |
| Exceeded €18,750 during the current year | Immediately, from that moment | 15 working days from crossing |
If you are having a good year, €18,750 is the number to watch, not €15,000.
What changed in 2025?
Decreto-Lei n.º 35/2025 of 24 March rewrote this part of the code to implement the EU small business scheme, and it made the regime wider, not narrower.
More people can now use it. Previously the exemption was closed to anyone with organised accounting, anyone doing imports, and anyone dealing in the goods and services listed in Annex E. All three groups can now qualify, provided they meet the turnover condition.
There is now a cross-border version. If you are established in another member state you can use Portugal’s exemption, provided your EU-wide turnover stays under €100,000, you notify your home member state first, and you obtain an identification number with the EX suffix. The same works in reverse for Portuguese-established freelancers operating elsewhere in the EU.
A second decree changed the one-off rules the same day. Decreto-Lei n.º 49/2025 of 27 March abolished the ato isolado registration threshold and moved one-off invoicing onto AT’s own applications, both with effect from 1 July 2025. Two separate instruments, one commencement date – which is part of why the old numbers have proved so persistent.
⚠️ The old regime closed to non-established taxable persons on 1 July 2025. If you were relying on it from outside Portugal, that route no longer exists and the cross-border scheme above is the replacement.
So which number is yours?
- Ongoing freelance activity, invoicing regularly → €15,000, and watch €18,750
- One genuine one-off job, no ongoing activity → no registration at any value since 1 July 2025, invoice through AT’s own applications, and IVA applies either way
- Established elsewhere in the EU, working into Portugal → the cross-border scheme and its €100,000 EU-wide ceiling
The €15,000-versus-€25,000 argument used to be two correct answers to two different questions, colliding in the same comment thread. It is not that any more. €15,000 is current; €25,000 is a rule that was repealed over a year ago and is still being repeated with total confidence. If someone quotes it at you, they are working from a version of the code that stopped applying on 1 July 2025.
