CAE vs CIRS Portugal: What Activity Code Do You Actually Need as a Designer?

The search query "CAE 1336 Portugal" or "activity code designer freelance" typically returns generic guides that don't address the core problem: 1336 is a code in the table of Article 151 of the IRS code (CIRS), not a CAE code, and the two systems are separate.

That distinction matters practically. The activity you register and declare governs your IRS coefficient, your withholding rate, and your whole simplified-regime calculation. Getting it wrong doesn't just cause an administrative headache: it can leave you paying the wrong amount of tax every year without realizing it.

Two systems for two kinds of activity

CAE (Classificação Portuguesa de Atividades Económicas) is Portugal's classification of economic activities, aligned with the EU's NACE classification. Its current version, CAE-Rev.4, has applied since 1 January 2025. It is the classification used for commercial, industrial and agricultural activity, and a company registers its activity with a CAE.

The Art. 151 table is the list the IRS code uses for liberal and professional services: Portaria n.º 1011/2001, Anexo I. When you open your activity at the Portal das Finanças as a sole-proprietor freelancer providing professional services, you pick a code from this table.

A freelance designer may have only a CIRS code, with no CAE at all. Some freelancers have both, for example when they also sell goods. The two numbers are never interchangeable: 1336 means nothing in the CAE, and a CAE code is not an Art. 151 code.

The CAE glossary entry covers both systems side by side, and the CIRS glossary entry explains the broader context of how the Art. 151 table fits into Portuguese tax law.

What CIRS 1336 says

Code 1336 in the Art. 151 table is "Designers", added to the table by Lei n.º 53-A/2006. The table gives only that one-word designation, not a list of who fits it. What decides your classification is the design work you actually perform.

Three adjacent codes come up in the same searches:

CIRS 1332 ("Programadores informáticos"). If you write and ship code as well as design, you may have both activities. You can register a principal activity and secondary ones, so a developer-designer hybrid can carry 1332 and 1336 together. See the CIRS 1332 guide for the full breakdown.

CIRS 1313 ("Analistas de sistemas"). Same table, same group.

CIRS 1320 ("Consultores"). See the CIRS 1320 guide.

All four are specifically listed, so all of them take the same 0.75 coefficient. Which one fits is a question about what you actually do, and for tax purposes nothing changes between them.

There is also CIRS 1519 ("Outros prestadores de serviços"), the catch-all for professions not specifically named in the Art. 151 table. Its coefficient is 0.35, so it makes only 35% of your gross taxable where 1336 makes 75% taxable. On paper it looks like the cheaper code. It is not a choice. Designers are specifically named in the table, so 1336 is the code that applies, and AT classifies income on the activity you actually perform rather than the code you filed. A designer sitting on 1519 is not saving tax: they are under-declaring, and the fix is a declaração de alterações to the right code.

The tax mechanics for CIRS 1336 designers

The 0.75 coefficient. Designers are specifically listed in the Art. 151 table, so under the simplified regime 75% of your gross revenue is taxable. The rest is treated as assumed business costs, and you can't swap it for your actual expenses even if your real costs were higher.

First-year discount. For services, the coefficient is cut by 50% in the calendar year you start and by 25% in the next one. For a listed activity like design that means 37.5% taxable in year one and 56.25% in year two. It runs by calendar year, not 12 months from your start date: open your activity in March rather than October and you get ten months at the year-one rate instead of three.

Each year is tested on its own: employment or pension income (Category A or H) in a year loses that year's cut. And you get neither cut if you closed any activity (cessação de atividade) in the previous five years, whatever that activity was.

The part that needs proof. 15% of your gross services income has to be covered by documented expenses, your Social Security contributions, or the automatic specific deduction (dedução específica, €4,587.09 (2026) in 2026). Contributions count only up to 10% of gross and do not stack on the specific deduction: the larger of the two counts. Any shortfall is added back to your taxable income. See the expense proof rule fact page for the full mechanics.

Social Security contributions. The part of your contributions above 10% of gross services income is deducted from your taxable income after the coefficient. The part up to that share only counts toward the proof above.

Withholding from Portuguese clients. A Portuguese client that has, or must have, organised accounting (every Portuguese company does) withholds 23% for activities specifically listed in the Art. 151 table and sends it to AT. Since 1 January 2025, that's the rate (reduced from 25% by OE2025, Lei 45-A/2024, Art. 101 CIRS). Private individuals don't withhold. If you expect your income this year to stay under the Art. 53 threshold of €15,000, and you did not reach it last year, you can claim a dispensation instead.

Withholding from foreign clients: normally nothing. This is the point that catches expat designers most off guard.

When your Berlin agency or Amsterdam client pays you €6,000 for a brand identity, no Portuguese tax is withheld. The IRS liability on that income is real. Budget for it, and expect IRS payments on account (pagamentos por conta) in July, September and December once your clients stop withholding enough to cover your tax. They are computed from your assessment of two years back, so they lag behind your first years of activity.

The expat designer layer

Most guides covering CIRS 1336 are written for Portuguese designers working primarily with Portuguese clients. If you moved from Sweden, the Netherlands, Germany, or the UK and your client base is back home or spread across Europe, several of those guides quietly stop applying to you.

Your old invoicing software is not legal here

If you issue Portuguese invoices with software, that software must be AT-certified (Decreto-Lei 28/2019). Certified software assigns ATCUD codes to every document, communicates with AT systems, and generates the SAF-T audit file.

FreshBooks and similar foreign tools are not AT-certified and cannot serve as your Portuguese invoicing system. This applies to CIRS 1336 designers the same as everyone else.

The free fallback is AT's own invoicing app on the Portal das Finanças ("Faturas e Recibos Verdes"). It is not certified software but a separate legal route, and its documents are in Portuguese only. For more on what to look for, see the expat freelancer tax automation guide.

Invoicing EU clients: no Portuguese VAT, but still obligations

When you invoice a business client in another EU country, the place of supply is the customer's country (Art. 6 CIVA), so no Portuguese VAT is charged: you use the reverse-charge code 115 and they account for the VAT where they are.

If you are in the normal VAT regime, you also file the Declaração Recapitulativa for those invoices, on the same cadence as your VAT return. Under the Art. 53 exemption you no longer do: DL 35/2025 revoked the provision that extended that obligation to exempt taxpayers, so operations carried out from 1 July 2025 onward are left out of the recapitulativa.

See the Art. 53 exemption glossary entry for the full scope.

Foreign software subscriptions: reverse-charge

When a supplier with no establishment in Portugal sells you a business service taxed where you are, as most software subscriptions are, Art. 2.º n.º 1 e) CIVA makes you the person liable for the VAT (sujeito passivo). If the supplier invoices you without VAT, you self-assess it through your Declaração Periódica.

Art. 53 status does not exempt you from it.

Practical consequence: if you have only Portuguese clients and no foreign suppliers, you likely have no Declaração Periódica to file under Art. 53. In a period where you do self-assess VAT on a foreign subscription, you file one.

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The compliance picture for a CIRS 1336 designer with foreign clients: certified software or AT's own app for your invoices, no Portuguese VAT on EU B2B invoices (with the Declaração Recapitulativa if you are in the normal VAT regime), a Declaração Periódica for any period with reverse-charge VAT on foreign tools, your own tax provision because foreign clients don't withhold, and your Social Security declarations. None of it is complicated once you know it exists.

Descodify's Completo plan (€19/month) prepares your VAT, Social Security and IRS paperwork.

Start at descodify.pt.

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