How to invoice a client in Portugal (2026)
A 2026 guide to invoicing a Portuguese client from Spain: when the invoice carries no VAT, reverse charge, ROI registration, VIES, Modelo 349 and the OSS threshold.
TL;DR: Invoicing a B2B service to a Portuguese company with a valid VAT number is done without Spanish VAT: the service is located at destination (art. 69.Uno.1º of Law 37/1992) and the client self-assesses the tax in Portugal under the reverse charge, per Portuguese law transposing art. 196 of Directive 2006/112/EC. To do it you must be registered on the ROI (Modelo 036) and report the operation on Modelo 349. If you sell to a Portuguese consumer, everything changes: the common €10,000 threshold (distance sales and digital services only) and the One-Stop Shop (OSS) apply.
Key takeaways
- A B2B service to a Portuguese company with a valid VAT number is not subject to Spanish VAT (art. 69.Uno.1º of Law 37/1992): you invoice without VAT and the client self-assesses the tax in Portugal under the reverse charge, per Portuguese law transposing art. 196 of Directive 2006/112/EC.
- Before you invoice, you must be registered on the ROI. You apply with Modelo 036, ticking box 582 (registration) and entering the expected date of your first operation in box 584. Your VAT number is your NIF with the prefix ES. If AEAT does not resolve within 3 months, it counts as denied.
- The operation is reported on Modelo 349. It is monthly, unless the amount does not exceed €50,000 (VAT excluded) in the reference quarter or in any of the four previous ones, in which case it is quarterly. It is not filed for periods with no operations.
- The special place-of-supply rules in art. 70 of Law 37/1992 (real estate, cultural or sporting events, restaurant services supplied on site) can change where the service is located even if the client is Portuguese: check them before invoicing.
- If your client is a private individual (B2C), the common €10,000 annual threshold applies, aggregated across the whole EU: below it you charge Spanish VAT; above it, Portuguese VAT, declared through the One-Stop Shop (OSS, Union scheme, Modelo 369).
Contents
You win a client in Portugal, the work is scoped, and then the invoice stalls on the VAT line. Short answer: if your client is a Portuguese company with a valid VAT number, that invoice goes out with no Spanish VAT. The service is deemed supplied in Portugal, and the client settles the tax there under the reverse charge. But to do it properly — and to survive a tax check — you need three things in order: registration on the ROI, verification of your client in VIES, and reporting the operation on Modelo 349. This guide covers the full 2026 flow for a Spain-based freelancer or company, with the variants that matter: a service to a business, a sale of goods, and a sale to a consumer.
The rule that decides everything: the service is located in Portugal
Intra-community VAT rests on one principle: for business-to-business (B2B) services, the tax is paid in the customer’s country, not the supplier’s. When a Spanish freelancer or company supplies a service to a Portuguese business, that service is deemed supplied where the customer is established — Portugal — under the general rule of art. 69.Uno.1º of Law 37/1992 (the Spanish VAT Act). The consequence: it is not subject to Spanish VAT.
That mechanism is the reverse charge (inversión del sujeto pasivo). The Portuguese client applies it under Portuguese law transposing art. 196 of Directive 2006/112/EC; art. 84 of Law 37/1992 describes the same concept in Spanish law, for the mirror case (a Spanish business receiving the service). In practice it means three things:
- You do not charge VAT on the invoice.
- Your Portuguese client self-assesses the VAT in Portugal, applying its own rules and rate.
- You keep the right to deduct the input VAT you incurred to provide the service.
This applies to professional services — consulting, development, design, marketing, recorded training, and the like. For the full mechanics, see the guide to reverse charge and Modelo 349.
Before the first invoice: ROI and VIES
The most expensive beginner’s mistake is issuing the VAT-free invoice before the paperwork is in order. Without the ROI, or without validating the client, the operation fails the conditions for non-taxation, and AEAT can claim the VAT you never charged, plus surcharges and interest.
1. ROI registration (Register of Intra-Community Operators). You apply through the census declaration, Modelo 036, ticking box 582 (registration request) and entering the expected date of your first operation in box 584. On registration, AEAT assigns you a VAT number that prefixes ES to your NIF and lists you in the VIES system. Mind the timeline: the administration has three months, and if it passes with no answer the VAT number is treated as denied (negative silence). Apply with margin.
2. Client validation in VIES. Before issuing, check in VIES that your Portuguese client’s VAT number (prefix PT) is valid and active. This is a legal condition, not a nice-to-have: if the client does not give you a valid VAT number, you cannot treat the operation as an intra-community, non-taxable supply, and you would have to charge Spanish VAT. Keep proof of each check with its date; it is your evidence in an audit.
How the invoice to Portugal is issued
The invoice to your Portuguese client looks like a domestic one, with two differences: no VAT line, and one legal mention. It must include:
- Your VAT number (ES + your NIF) and the client’s Portuguese VAT number (PT + their number).
- The taxable base, with no Spanish VAT.
- An express mention that the operation is subject to reverse charge (inversión del sujeto pasivo).
A worked example
A freelance developer in Seville invoices a software project to a company in Lisbon for €4,000. She is already on the ROI and has validated the client’s Portuguese VAT number in VIES. Her invoice:
| Item | Amount |
|---|---|
| Taxable base (software development) | €4,000.00 |
| Spanish VAT | — not charged |
| Invoice total | €4,000.00 |
| Mandatory mention | ”Reverse charge” (inversión del sujeto pasivo) |
The Lisbon company receives the invoice for €4,000, with no Spanish VAT, and self-assesses Portuguese VAT at the rate in force there. The developer collects the full €4,000 free of VAT, but that income still counts toward her income tax (IRPF, or Corporate Income Tax if the issuer is a company): a VAT-free invoice does not mean tax-free income. And an invoice to a Portuguese client carries no Spanish IRPF withholding, because a non-resident client does not act as a withholding agent for Spanish income tax.
Modelo 349: frequency and deadlines
Every supply of services to a business customer in another member state is reported on Modelo 349, the recapitulative statement of intra-community operations (approved by Order EHA/769/2010). It is an information return: it generates no payment, it only cross-references data between EU tax administrations. The obligation reaches every business or professional with intra-community operations, regardless of VAT regime, and it is not filed for periods with no operations.
Frequency turns on one threshold: €50,000 (VAT excluded). It is monthly by default; it becomes quarterly only if the total value of supplies of goods and services to be reported does not exceed that limit in the reference quarter or in any of the four previous calendar quarters. If the threshold is crossed within a month, you return to monthly filing. The deadlines:
| Period | Filing deadline |
|---|---|
| Monthly (general rule) | First 20 calendar days of the following month |
| July | During August and the first 20 calendar days of September |
| December / final period of the year | First 30 calendar days of January |
These supplies also appear in the information box of your quarterly Modelo 303: they do not change the amount due, but they must reconcile with what you reported on the 349. If you split your activity between Spain and the EU, it helps to review how it all fits together in the guide to quarterly VAT for freelancers who invoice the EU.
When the treatment changes: special rules and goods
Everything above assumes an ordinary service. Two situations break the pattern and are worth spotting before you invoice.
Special place-of-supply rules (art. 70 of Law 37/1992). Even if the client is Portuguese, some services are located by criteria other than the customer’s seat: those connected to real estate (located where the property is), cultural, artistic or sporting events, and restaurant services supplied on site. If your service fits any of these, the treatment can change: check your case in AEAT’s service place-of-supply locator before issuing. Do not settle for “almost certainly VAT-free” — that is exactly where the costly mistakes happen.
Sale of goods (not services). If you ship goods to Portugal rather than supply a service, the operation is an intra-community supply of goods, which is exempt from VAT in Spain (art. 25 of Law 37/1992) when the buyer provides a VAT number from another member state and the goods are actually transported there. It is taxed at destination, it keeps your right to deduct input VAT, and it is also reported on Modelo 349. The evidential key is transport: without proof the goods left for Portugal, the exemption wobbles, so keep the carrier’s documentation. The administrative circuit — ROI, VIES and the 349 — is the same as for services.
B2B versus B2C: when the OSS appears
Everything above assumes your client is a business or professional with a VAT number. If you invoice a private individual in Portugal (B2C), the circuit is different: there is no reverse charge.
For intra-community distance sales of goods and for digital services (telecommunications, broadcasting and electronic services), a common threshold of €10,000 (VAT excluded) applies — and it matters to read it correctly: it is not per country, but aggregated across all your distance sales and digital services in the whole EU, measured over the previous year or the current one. Below it, you tax in Spain with Spanish VAT; above it, you tax in the country of consumption — Portugal — and you can declare it through the One-Stop Shop (OSS, Union scheme, Modelo 369), a single registration that saves you from registering country by country. You may opt to tax at destination even without crossing the limit. The OSS and the €10,000 threshold come from Royal Decree-law 7/2021; Modelo 369 was approved by Order HAC/610/2021.
| B2B (Portuguese company) | B2C — distance sale of goods or digital service | |
|---|---|---|
| VAT on the invoice? | No (reverse charge) | Depends on the threshold |
| Relevant threshold | €50,000 → Modelo 349 frequency | €10,000 → taxation at destination |
| Who settles the VAT | The client, in Portugal | You, in Portugal (via OSS) or in Spain |
| Reported on | Modelo 349 | OSS (Modelo 369) once above the threshold |
The €10,000 threshold and the OSS only apply to distance sales of goods and digital services (telecommunications, broadcasting and electronic services). A non-digital B2C service — consulting to a private consumer, for example — does not fall under that regime: it carries Spanish VAT at origin (art. 69.Uno.2º of Law 37/1992), with no threshold and no OSS.
If you sell products or digital services to consumers, the detail is in the guide to EU VAT on digital services and the OSS. And if your activity includes clients outside the EU, the treatment changes again: we cover it in the guide to exporting services outside the EU.
Common mistakes when invoicing Portugal
How Frihet automates it
Invoicing Portugal adds steps that are easy to forget when you run the operation by hand. With Frihet you issue the invoice already free of Spanish VAT and with the reverse-charge mention built in, and the operation is flagged as intra-community so the Modelo 349 data is ready when it is time to file, with the right reflection in your Modelo 303. Frihet calculates and prepares the VAT, IGIC and IRPF treatment your activity needs from your own invoices and expenses — VeriFactu operation included — with OCR expense capture and a real-time financial dashboard behind it.
What Frihet does not do for you: ROI registration and filing the 349 remain steps you or your adviser handle with AEAT. What it does prevent is an invoice going out malformed, or an EU sale left un-reconciled. Invoicing a client in Portugal is not complicated: it becomes routine the moment you are on the ROI, validate the client, and know which mention to add. The first invoice takes a little longer; from the second, it is a two-minute job.
This guide is informational and reflects the rules in force in 2026. For cases with special rules (real estate, events) or doubts about your specific situation, confirm with AEAT’s electronic office or your adviser.
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FAQ
Do I charge VAT on an invoice to a client in Portugal?
If the client is a Portuguese business or professional with a valid VAT number, no. Under the general place-of-supply rule for B2B services (art. 69.Uno.1º of Law 37/1992), the service is deemed supplied where the customer is established — Portugal — and is not subject to Spanish VAT. You issue the invoice without VAT and the client self-assesses the tax in Portugal. If the client is a consumer, the answer changes and depends on the €10,000 threshold.
Do I need to be on the ROI to invoice Portugal without VAT?
Yes. To operate VAT-free with EU businesses you must be identified on the Register of Intra-Community Operators (ROI), which lists you in the VIES system and assigns you a VAT number with the prefix ES. You apply with Modelo 036, ticking box 582 and stating the expected date of your first operation in box 584.
How do I report the invoice to Spain?
An intra-community supply of services is reported on Modelo 349, the recapitulative statement of intra-community operations. It is an information return — it does not generate a payment. It is monthly, unless you stay below €50,000 (VAT excluded) in the reference quarter and each of the four previous ones, in which case it is quarterly.
What must the invoice to Portugal say?
It must show your VAT number (prefix ES) and the client's (prefix PT), the taxable base without any Spanish VAT, and an express mention that the operation is subject to reverse charge (inversión del sujeto pasivo).
How do I check that the Portuguese VAT number is valid?
By checking your client's number (prefix PT) in the European Commission's VIES system before issuing the invoice. A valid VIES number at the moment of invoicing is the condition for treating the operation as intra-community and VAT-free. Keep the proof of the check with its date.
What if my Portuguese client is a consumer, not a company?
Then there is no reverse charge. The common €10,000 annual threshold applies, aggregated across all your EU distance sales and digital services. Below it you charge Spanish VAT; above it you charge Portuguese VAT and can declare it through the One-Stop Shop (OSS, Modelo 369) without registering in Portugal.
