Invoicing EU Clients from Portugal: VIES, Reverse Charge, and What Your Invoice Must Show

A client in Germany sends you their VAT number. You add it to the invoice, mark VAT at zero, include a line about reverse charge, and send it. Most of the time, this works fine. Sometimes you've skipped the step that determined whether you were allowed to do it.

The reverse charge on EU B2B services is real and does what people expect: VAT liability shifts to your client, you invoice at zero, nothing to remit to Portugal. But it turns on a fact you have to establish: that your client is a taxable person in their own country. A VAT number confirmed as active in VIES at the time you issue the invoice is the evidence you rely on for that.

What VIES checks, and why it matters

VIES stands for VAT Information Exchange System. It is the EU database where each member state publishes active VAT registrations for cross-border verification. You enter a VAT number with the country prefix, and VIES returns one of two results: the number is active, or it is not.

Active means the registration is current in the foreign member state's system. Not active means it is wrong, expired, or for some reason not showing as a live registration. Companies dissolve. VAT registrations lapse. Clients sometimes give you last year's format or a number that was active when they first registered you as a supplier and has since changed.

A client who tells you they are VAT-registered, and sends you what looks like a correct number, is not the same as a VIES-confirmed registration. The law conditions on your client's status, not on their registration. Art. 6.º n.º 6 a) CIVA points to a taxable person "dos referidos no n.º 5 do artigo 2.º", and the first limb of that provision reaches anyone independently and habitually carrying on a business, with no condition that they be registered anywhere. VIES is how you evidence the finding, not what creates it, so without a confirmation you are not forbidden to apply the reverse charge, you are carrying the burden of proving your client's status yourself.

What you do when it fails depends on your regime. In the normal VAT regime you charge Portuguese VAT, on the mainland currently 23% for most services. Under the Art. 53 exemption you charge none, and the invoice carries exemption code 122. That is the failed-VIES case only: a B2B service to a confirmed taxable person elsewhere in the EU is outside Portuguese VAT altogether and carries 115 whatever your regime, because the place-of-supply rule decides where the service is taxed and Art. 53 exempts only operations located in Portugal. AT says so directly in ficha doutrinária n.º 12969 (despacho de 2018-01-04): independentemente of the supplier's regime, that invoice takes the autoliquidação mention. Read that ruling's § 14 with the date in mind, though: it also says an Art. 53 taxpayer files the recapitulativa whatever their regime, which was true when it was written and was revoked by DL 35/2025.

This is the step that gets skipped in informal invoicing setups: VIES is checked once, or not at all, and the assumption is that anything claiming to be a business client qualifies.

What your invoice must say

Assuming VIES confirms the number as active, one phrase is required and a second is worth printing beside it.

"IVA - autoliquidação" is the Portuguese statutory reference. It comes from Art. 6.º n.º 6 alínea a) do CIVA, a contrário: the place-of-supply rule that puts an intra-EU B2B service outside Portuguese VAT, so the liability lands on your client instead. In certified invoicing software, exemption code 115 maps to this. The phrase must appear on the invoice, not just be implied by a zero VAT line, and it stays in Portuguese whatever language the rest of the invoice is written in.

(Art. 2.º n.º 1 e) CIVA is a different rule that often gets quoted here by mistake. It is the mirror case: it makes you liable for the VAT when you buy services from a foreign supplier like AWS or Stripe. It is not the basis for the mention on an invoice you issue.)

"Reverse charge" is the EU-level reference, from Art. 226(11a) of the EU VAT Directive. Portugal transposes that requirement as autoliquidação, so a Portuguese-language invoice is compliant on its face with the Portuguese mention alone. Print the English one alongside it anyway. Your German client's accounts-payable process needs this phrase to book the invoice correctly and apply their domestic reverse charge. The Portuguese AT reference satisfies your compliance; the EU Directive reference is what makes the invoice work for your client.

Beyond those two phrases, the client's VAT number must include the two-letter country code: DE for Germany, FR for France, NL for the Netherlands, and so on. Not just the digits. DE123456789, not 123456789. The country prefix is part of the VAT number format defined by the Directive, and it is what VIES uses to route the lookup to the right member state.

The Declaração Recapitulativa

Separate from the invoice itself, there is a periodic filing obligation: the Declaração Recapitulativa. It is a report listing each EU business client, their VAT number, and the total amount you invoiced them in the period.

Whether you file it at all now depends on your VAT regime. In the normal regime you file from your first EU B2B invoice, not when your turnover reaches some other level. Submission is through the AT portal.

Under the Art. 53 exemption you no longer file it. DL 35/2025 revoked the provision that extended the obligation to exempt taxpayers, so operations carried out from 1 July 2025 onward are excluded. Supplies made up to 30 June 2025 were reportable, and the obligation for those earlier periods still stands.

Your filing cadence follows your VAT cadence, which for most freelancers is quarterly. A common piece of misinformation says the cadence switches to monthly once your EU sales pass €50,000. That threshold is real, but it counts intra-EU sales of goods only. Services sit outside the count entirely, so if you sell services you stay on your VAT cadence no matter how much you invoice. The threshold matters if you ship goods into the EU, and not otherwise.

If you have been invoicing EU business clients and have not been filing the recap statement, the correction path depends on how many invoices are involved and over what period. Worth going through with a contabilista certificado before you start filing retrospectively.

When VIES returns invalid

VIES failures are not always definitive. National databases do not always update in real time. A newly registered client might not appear in VIES for a few days. The VIES system itself occasionally times out rather than returning a clear result.

The practical rule: confirm the number before you rely on the reverse charge, and re-confirm rather than trusting a result you stored months ago. If you cannot get a confirmation at the time of invoicing, you are issuing on a finding you cannot yet evidence.

If a client's number comes back definitively invalid, you lose the safe harbour VIES gives you. The law still turns on whether your client is in fact a taxable person, so you can only keep treating them as one on other evidence you can stand behind. Where you can't, the service is treated as one to a private person and is located in Portugal: a normal-regime invoice includes Portuguese VAT, and under Art. 53 it carries the exemption code 122 instead. Your client may be able to recover Portuguese VAT on their side depending on their situation.

How Descodify handles this

A recent fix corrected a gap in how reverse charge was applied. Previously, the system could apply reverse charge based on a stored client profile without re-confirming that the VIES validation was current at invoice time. The fix separates the three states rather than gating on one. A number that comes back invalid is treated as no evidence of business status: in the normal regime the invoice flips to the normal rate, and under Art. 53 it falls back to code 122 with a warning. A number that has simply not been checked still gets the reverse charge and raises a warning, because a check that has not run yet is not a check that failed, and refusing to issue on it would be the wrong failure.

This is not a new rule. Relying on a VIES confirmation has been part of EU VAT law for years: Art. 18 of Implementing Regulation (EU) No 282/2011 lets a supplier treat a customer as a taxable person once the customer has given a VAT number and the supplier has confirmed that the number, and the name and address that go with it, are valid, unless the supplier has information to the contrary. It is a presumption you may rely on, not a box the law makes you tick, and it only protects you while the confirmation is current. But it is easy to build a workflow that checks VIES once, saves the result, and assumes it is permanent. VAT registrations are not permanent.

What this looks like in practice

For most freelancers with EU business clients, the workflow is:

Your client provides their VAT number including the country prefix. You look it up in VIES before creating the invoice. VIES confirms active. The invoice shows zero VAT, "IVA - autoliquidação", and "Reverse charge". The client's number appears in full. If you are in the normal VAT regime, you then file the Declaração Recapitulativa covering that client for the period.

If VIES returns invalid or the client has no number, and you have no other evidence you can stand behind that they are a business, a normal-regime invoice includes Portuguese VAT, 23% on the mainland (under Art. 53, code 122 instead). The client may need to provide a corrected number, or they pay the VAT and handle recovery on their end.

The mechanism itself is clean. The VIES step is what separates a compliant EU B2B invoice from one that looks right but is not.

Related: Invoicing foreign clients as a solo entrepreneur in Portugal, the full breakdown of document types and the two-step fatura-receipt workflow.

Related: VAT in Portugal for freelancers, when the Art. 53 exemption applies.

Related: How to invoice a foreign client in English from Portugal, why the AT portal generates Portuguese-only documents even with the interface set to English.