When do I have to register for VAT in Portugal in 2025?

(New €15 000 / €18 750 limits explained for residents, non-residents, companies, freelancers and AL hosts)

In July 2025 the Portuguese Tax Authority made the biggest shake-up of the small-business VAT (IVA) exemption in over a decade. If you:

own a Portuguese Lda,
invoice clients as an independent worker (Independent Activity/”Green Receipts”), or
own an Alojamento Local (AL) short term rental property

The reform decides exactly when you must register for VAT. If you miss the registration dates you risk back-dated tax and late-filing penalties that everyone would rather avoid. This guide explains the new thresholds, the updated deadlines, and how they apply to real-world situations—so you can plan ahead.

1. The two magic numbers you need to memorise

Limit	What it means	When it matters
€15,000	Maximum Portuguese-located turnover to stay VAT-exempt for a full calendar year.	Tested on 31 December 2025 (and every 31 Dec after that).
€18,750	25% “safety buffer”. If you exceed this during 2025, VAT kicks in immediately.	Tested invoice-by-invoice throughout 2025

Important: Only sales located in Portugal count. Invoices to foreign clients—usually issued with reverse-charge code M40—remain outside the calculation.

Also Important: Non-EU residents must become VAT registered regardless of turnover. If you are a non-EU resident and you’re earning money in Portugal, your activity must be VAT registered.

Are you an AL owner in Portugal? Know all about “How do the New VAT Rules Impact My AL?”

2. Decision map for the 2025 transition year

A) You live in Portugal

Profile	Portuguese turnover in 2025	What to file	When to file	VAT starts
LDA Owner	≤ €15,000 €15,001 – €18,750 > €18,750 (breached mid-year)	Nothing (stay exempt) Declaration of Alterations Declaration of Alterations	– Within the first 15 working days of January 2026 15 working days after the trigger invoice	– 1 Jan 2026 On the trigger invoice itself
Independent activity (freelancer	Same thresholds and deadlines as above.	–	–	–
AL owner	Turnover = rental income located in PT. Same thresholds, but VAT rates are 6 % / 13 %.	–	–	–

B) You do not live in Portugal

Your Tax Residence	Exemption status 1 Jan – 30 Jun 2025	From 1 Jul 2025	Filing Deadline
EU/EEA	Same thresholds as residents.	Choose one: 1. Normal Portuguese regime (register & file). 2. Cross-border exemption (close PT VAT, file quarterly SME return at home).	• Option 1: Declaration of Alterations by 30 Jul 2025. • Option 2: Declaration of Cessation dated 30 Jun 2025, filed by 30 Jul 2025.
Non-EU/EEA (UK, US, Brazil…)	Same thresholds until 30 Jun.	Must join the normal Portuguese VAT regime—exemption ends automatically	Register or file alteration by 30 Jul 2025.

3. Common real-world scenarios

Scenario	Do I register?	Why
UK-resident owns an AL in Lisbon earning €10,000 in 2025	Yes – register by 30 Jul 2025.	Third-country rule overrides the turnover limit.
German graphic designer in Porto bills €22,000 to Berlin clients, €12 000 to PT clients in 2025.	No – stay exempt for 2025.	Only €12,000 counts toward the cap.
Lisbon Lda earns €16,000 in Portugal + €4 000 abroad in 2025	Alteration by mid-Jan 2026.	Portuguese turnover €16,000 > €15,000.
Portuguese freelancer exceeds €18,750 on 14 Oct 2025 with a local project.	AT on that 14 Oct invoice + alteration within 15 working days.	Real-time trigger breached.

4. How to stay compliant (and keep life simple)

Use the right invoice codes
- M10 – exempt domestic sales under article 53.
- M40 – reverse-charge services to foreign clients (0 % PT VAT).
Budget for VAT – collecting VAT also lets you deduct it on renovations, software, utilities.
Consult an Accountant in Portugal – a brief chat with an English Speaking Accountant can save hours of re-invoicing and potential fines.

5. Quick FAQ

Do foreign-client sales count toward the €15 000 limit?

No. Only Portuguese-located sales are tested.

Can I opt into the exemption in 2025 if I’m already in the normal regime?

Yes—there’s a one-time window in June 2025 to file and switch. The exemption applies from 1 July 2025 if your 2024 Portuguese turnover was ≤ €15 000.

What if I miss the January 2026 deadline?

The Tax Authority may back-charge VAT from 1 January 2026 plus interest and penalties. File as soon as you realise and pay voluntarily to reduce fines.

Need personalised guidance?

Each case is unique, and the paperwork has tight turnarounds. An English Speaking Accountant who specialises in foreign-owned Portuguese businesses can set up the right invoices, handle the filings and let you focus on running your company, freelance gig or AL property.

Based solely on the OCC “Guia Prático – Regime Especial de Isenção do IVA” (July 2025). Always confirm your specific situation with a professional adviser.