VAT

VAT exemption under article 53: the €15,000 limit

By Simples IRS teamPublished 11 November 2026Updated 11 November 20265 min read

Conditions

You are exempt from VAT under CIVA, article 53(1) if you meet all three conditions at the same time:

You are domiciled in Portugal.
You do not export or carry out activities linked to exports.
In the previous calendar year, your turnover in Portugal was not more than €15,000. This is the total of sales and services, without VAT (CIVA, article 52-A).

If you start your activity this year, there is no previous year: what counts is your expected turnover for the current year, which you state in the start of activity declaration (CIVA, article 53(5)). The exemption also does not apply to anyone who carries out a single transaction, the so-called ato isolado (one-off transaction) (paragraph 6 of the same article).

Being exempt has a downside: you cannot deduct the VAT you pay on purchases for your activity (paragraph 3 of the same article).

When you go over the limit

Turnover in the year	What happens
Up to €15,000	You stay exempt.
More than €15,000, up to €18,750	Exempt until 31 December; normal regime from 1 January. Change declaration (declaração de alterações) within 15 working days from the last day of the year.
More than €18,750	You leave immediately: the invoice that takes you over this amount already includes VAT. Change declaration within 15 working days from that moment.

The rules are in CIVA, article 58(2), (4) and (5) and the AT explains them in its AT newsletter of January 2026. You do not have to pay back VAT on old invoices: the tax is only due from the moment the law sets.

Worked examples

The status in each example was worked out with the same function as the VAT exemption checker.

1. Close to the limit, but still exempt

In 2025 you invoiced €9,000. In 2026 you are already at €14,200. You stay exempt and have €800 of headroom up to €15,000.

2. €2,000 a month, every month

In August the total reaches €16,000: you have gone over €15,000, but not €18,750. For now, you keep invoicing without VAT.
In September you are at €18,000, still below €18,750.
The October invoice takes the total to €20,000. That invoice already includes VAT, and so do all the following ones.
If that invoice is dated 14 October 2026, the 15 working days for the change declaration end, by our calculation, on 4 November 2026 (we counted working days without Saturdays, Sundays and national holidays).

3. You go over €15,000, but stay below €18,750

You close 2026 at €16,500. You stay exempt until 31 December 2026 and move to the normal regime on 1 January 2027. The change declaration is due within 15 working days from 31 December: by our calculation, by 22 January 2027.

4. Exactly €15,000 in the previous year

CIVA, article 53 refers to turnover «superior» (more than) €15,000. With exactly €15,000 in 2025, you stay exempt from VAT in 2026. But the IRS withholding tax exemption uses a different rule: it stops applying when you invoiced «igual ou superior» (equal to or more than) that amount in the previous year. See the withholding tax guide.

On the invoice

Every invoice without VAT must say why. The wording is «IVA - regime de isenção» (VAT – exemption regime) (CIVA, article 57(2)).

Exempt or not, you must still issue an invoice for every sale or service. If you use Faturas e Recibos on the Portal das Finanças, you do not have to report your invoices by the 5th of the following month, because the AT already has them (AT leaflet «Início de atividade»).

Step by step on the Portal das Finanças

Keep track of the year’s total in Faturas e Recibos, under «Consultar» (view). Add up the amounts without VAT since 1 January.
Issue the invoice that takes you over €18,750 with VAT already.
Log in to the Portal das Finanças with your NIF and password, or with the Chave Móvel Digital.
Open Atividade > Submeter declarações-início, alteração e cessação and choose the change declaration (declaração de alterações) (AT leaflet «Início de atividade»).
Change your VAT regime to the normal regime, with the date from which the change applies. Validate and submit.
Keep the confirmation.

Once you have left, you submit the periodic VAT return. With turnover below €650,000, it is every 3 months (CIVA, article 41(1)). See the dates in VAT deadlines.

Waiving the exemption and going back

Waiving: you can opt for the normal regime even if you meet the conditions. You then stay in the normal regime for at least five years (CIVA, article 55).
Going back to the exemption: if you met the conditions again in the previous year, you submit the change declaration in January and the exemption applies from 1 January of that year (CIVA, article 54).
Closing and reopening: if you cease your activity while in the normal regime and reopen within the next 12 months, you cannot be exempt (CIVA, article 56).

Common mistakes

Counting the wrong year: to be exempt in 2026, what counts is what you invoiced in 2025, not the average of the last 12 months.
Waiting until January after going over €18,750: the invoice that takes you over that amount already includes VAT.
Starting to export and keeping the exemption: with exports, you no longer meet the conditions.

Check my case

Frequently asked questions

Is the VAT exemption limit €15,000 in 2026?

Yes, €15,000 of turnover in the previous year, under article 53 of the VAT Code and the Finanças information of January 2026.

If I go over the limit, do I have to pay back VAT on old invoices?

No. VAT is only due from the moment set by law: the invoice that takes you over €18,750, or 1 January of the following year.

Does the limit include VAT?

No. Turnover is the total of sales and services in Portugal, net of VAT (CIVA, article 52-A).

I started my activity this year. Which amount counts?

Your expected turnover for the current year counts, as stated in the start of activity declaration (CIVA, article 53(5)).

How long do I have to tell the Finanças?

Fifteen working days, from the last day of the year in which you went over the limit, or from the moment you went over €18,750 (CIVA, article 58(5)).

Can I go back to the exemption after leaving?

Yes, if you meet the conditions again. You submit the change declaration in January and the exemption applies from 1 January (CIVA, article 54).

Official sources

Every figure on this page comes from these sources (official documents, in Portuguese). Updated on 11 November 2026