Two different things in Portuguese freelancing turn on €15,000. One decides whether your clients withhold IRS from what they pay you; the other decides whether you charge IVA at all. It is not a coincidence — the IRS provision states no figure of its own, it points at the IVA one — but they are still different rules with different consequences, and qualifying for one does not put you inside the other.
| IRS withholding | IVA exemption | |
|---|---|---|
| What it does | Removes your clients' duty to withhold | Removes your duty to charge IVA |
| Where | CIRS art. 101.º-B | CIVA art. 53 |
| Threshold | The IVA figure, by reference | €15,000 prior year |
| Mid-year trigger | — | €18,750 ends it immediately |
The withholding rates
| Activity | Rate | Provision |
|---|---|---|
| Professional activities (art. 151.º table) | 23% | art. 101.º n.º 1 b) |
| Other Category B activities | 11.5% | art. 101.º n.º 1 c) |
Withholding is not the tax. It is money taken on account and settled by the annual return, which means an over-withheld year comes back as a refund and an under-withheld one arrives as a bill.
A receipt for everything received
Since July 2025 the obligation is explicit: a receipt is due for every amount actually received. That includes the ones people assume are outside the system.
- A provisão — money held on account before the work.
- An adiantamento — a payment in advance.
- A reembolso — a reimbursement.
What does not enter the taxable base
- Expenses incurred in the client's name and reimbursed by them.
- The IVA you charged — it was never your income.
- A receipt cancelled (Anulado), and anything covered by a credit note.
The distinction matters more than it sounds. A freelancer who invoices €21,500 and passes through €3,000 of client-name expenses does not have €24,500 of income, and treating the reimbursement as turnover can push them across a threshold they never actually crossed.
Keeping the records
Books and supporting records are kept for ten civil years. That is the IVA rule, and it is longer than most people assume — a receipt from 2026 is still within reach in 2036.
What is the withholding rate on green receipts in Portugal?
23% for professional activities listed in the art. 151.º table, and 11.5% for other Category B activities. A 25% figure is out of date.
When am I exempt from withholding on recibos verdes?
The dispensation under CIRS art. 101.º-B applies below €15,000. It is a separate rule from the IVA exemption, which happens to use the same number.
Is the €15,000 IRS threshold the same as the IVA one?
It is the same figure — CIRS art. 101.º-B states no amount of its own and points at CIVA art. 53.º — but they are different rules. The IVA exemption additionally ends mid-year above €18,750, and the withholding dispensation is optional and has to be claimed on the receipt. Qualifying for one does not put you inside the other.
Do I have to issue a receipt for an advance payment?
Yes. Since July 2025 a receipt is due for every amount actually received, including a provisão, an adiantamento and a reimbursement.
Do reimbursed expenses count as my income?
Not when the expense was incurred in the client's name. Nor does the IVA you charged, nor a cancelled receipt or one covered by a credit note.
How long must green receipt records be kept?
Ten civil years, under CIVA art. 52.