Short answer: Article 53 can exempt your accommodation sales from VAT, but it does not automatically exempt you from VAT on services you buy. When a platform's commission qualifies for the reverse charge, an exempt host must self-assess and pay that VAT without deducting it.
The result depends on the supplier, the service, your VAT registration and the actual invoice. This guide covers the usual business-to-business case and the rules checked on 5 November 2026. Ask a Portuguese accountant to confirm your situation, particularly if your property and business are in different VAT territories.
For the broader picture, see our guide to VAT, cleaning fees and platform commissions.
What the Article 53 exemption covers
The small-business exemption means that qualifying hosts do not charge VAT on their exempt sales and generally cannot deduct VAT on purchases. You can request the regime when you open your activity with Finanças, provided you meet its conditions. The normal threshold is €15,000 of annual Portuguese turnover; calculate the taxpayer’s relevant total turnover, not just one property or platform. Other conditions also apply. The Tax Authority's activity and VAT guidance explains the rules.
If current-year turnover exceeds €15,000 but does not exceed €18,750, the exemption normally ends at year-end and the change takes effect the following year. If it exceeds €18,750, the exemption ends immediately, including on the transaction that crosses the limit. In the first case, file a declaration of changes within 15 working days after the year-end; in the second, within 15 working days after crossing the limit. Check your calculation and transition with an accountant.
What goes on the guest invoice?
While the exemption applies, your accommodation invoice carries no VAT and must include the applicable exemption reason, such as M10. Invoice the full amount for the accommodation and services you supply, before deducting your platform commission. A separate platform service fee charged by the platform to the guest is not automatically part of your own service. See how to issue a guest invoice on Finanças.
Why a platform commission is different
Booking.com or Airbnb may sell an intermediation service to the host. In the usual qualifying cross-border business-to-business case, Portuguese VAT is accounted for by the customer under the reverse-charge rules. An invoice issued to a correctly registered business VAT number may show no supplier VAT and indicate reverse charge. Check the contracting entity, VAT number, invoice and treatment; do not assume every platform invoice has the same result or pay VAT twice.
A host in the normal VAT regime may be able to deduct the VAT, subject to the ordinary deduction rules. An Article 53 exempt host generally cannot, so the self-assessed VAT is a cost. In binding ruling 25603, the host had reported Airbnb commissions in boxes 16 and 17; the Tax Authority addressed the subsequent cancellation.
How to deal with a qualifying reverse-charge commission
- Check your activity registration. Before acquiring intra-EU services, ensure your activity declaration reflects the relevant transactions. Confirm that your PT VAT number is valid for the transaction, including its status in VIES when relevant; do not assume that changing your declaration automatically resolves every registration issue.
- Check the correct rate. The commission is an intermediation service, not accommodation. In the usual case, standard rates are 23% on the mainland, 22% in Madeira and 16% in the Azores. The correct place and territory depend on the facts, so seek advice if the property and your establishment are in different regions.
- File and pay. For qualifying services acquired from suppliers in another EU country, an Article 53 host reports the commission and VAT in boxes 16 and 17 of quadro 06 of the periodic VAT return. The special filing and payment deadline is generally the end of the month following the month when the tax became due; see Article 27 of the VAT Code. An exempt host does not normally file routine periodic returns solely because of exempt sales; confirm other taxable transactions and filing obligations with your accountant.
- Keep the evidence. Save platform invoices, tax numbers, payment records, filings and any credit notes. Match each item to the relevant tax period.
What if a booking is cancelled?
A guest cancellation does not itself prove that a platform commission was reversed. If the platform actually reverses it, keep the cancellation and credit evidence and discuss the correction with your accountant. In the specific circumstances of ruling 25603, the AT described correcting the original period by a replacement return and requesting the overpayment through e-balcão. Do not assume that procedure applies unchanged to every case.
Worked examples
Suppose the platform issues a qualifying reverse-charge invoice for a €180 host commission. The VAT is:
| VAT territory | Standard rate | VAT on €180 |
|---|---|---|
| Mainland Portugal | 23% | €41.40 |
| Madeira | 22% | €39.60 |
| Azores | 16% | €28.80 |
For example, if a mainland host's VAT becomes due in March, the standard special deadline is the end of April. For a separate annual illustration, €12,000 of bookings at an assumed 15.5% host fee produces €1,860 in commission and €427.80 of mainland VAT at 23%. The figures are illustrative: actual platform fees and invoicing arrangements vary, and direct bookings can also have costs.
Does Modelo 30 also apply?
Modelo 30 is a separate income-tax reporting obligation. The Tax Authority's Modelo 30 guidance states the general deadline is the end of the second month after payment. The AT's ruling 11050 discusses platform commissions, reporting even without withholding, and treaty documentation in its circumstances.
Ask your accountant to assess the recipient, source of income, any withholding, and treaty relief and supporting documentation before filing. See our Modelo 30 guide for AL hosts.
Frequently asked questions
Does Article 53 exempt platform commissions from VAT?
No. The exemption covers your qualifying sales; when the conditions for reverse charge are met, you generally self-assess VAT on the service purchased and cannot deduct it.
Which rate applies to a qualifying commission?
The standard rate, normally 23% on the mainland, 22% in Madeira or 16% in the Azores. Confirm the territory and service classification for your circumstances.
Must I file a VAT return every quarter?
Not simply because your own sales are exempt. Qualifying reverse-charge transactions can require a periodic return for the relevant month. Other operations may create additional obligations.
Do I need Modelo 30 as well?
Commissions paid to non-residents may require Modelo 30 separately from VAT. Check the reporting, withholding and treaty documentation with your accountant.
What happens if I exceed €15,000?
If you stay at or below €18,750, the exemption normally ends at year-end. Above €18,750 it ends immediately, including the transaction that exceeds it. Different notification deadlines apply.
Keep the figures organised
Review platform invoices monthly, record qualifying commissions separately from guest revenue and share the supporting documents with your accountant. EazyAL helps hosts organise reservations and compliance work. Learn about direct bookings with EazyAL or view the plans.
