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Declaração recapitulativa (EU clients)

Who has to file it, when (earlier than the IVA return!), and how to fill it in.

If you invoice businesses in other EU countries, you don't charge them Portuguese IVA — the client pays VAT in their own country (autoliquidação / reverse charge). In exchange, Portugal wants to know who those clients are, so tax authorities can cross-check: that's the declaração recapitulativa. It lists each EU client's VAT number and how much you invoiced them.

Do I need to file it?

Yes, for every quarter in which you invoiced a service to a client that:

  • is a business registered for VAT in another EU country, and
  • the service is taxed there under the general B2B rule (art. 6.º, n.º 6, a) CIVA) — which covers most freelance work: software, design, consulting, translation, marketing…

This applies whether you're in the quarterly IVA regime or exempt under art. 53.º.

No, if in that quarter you only invoiced:

  • clients in Portugal,
  • private individuals (B2C) anywhere,
  • clients outside the EU (including the UK, USA, Switzerland),
  • services that are VAT-exempt in the client's country (e.g. financial or insurance services).

No EU invoices in a quarter → nothing to file for that quarter. There's no "zero" declaration.

When

Quarterly, by the 20th of the month after the quarter ends (art. 30.º RITI) — moved to the next business day if that's a weekend or holiday:

Quarter Due
Q4 (Oct–Dec) 20 January
Q1 (Jan–Mar) 20 April
Q2 (Apr–Jun) 20 July
Q3 (Jul–Sep) 20 October

This is a month before the IVA quarterly return, not on the same day. It's common to do both together in February / May / September / November — but by then the recapitulativa is already late.

The €50,000 rule that makes some people switch to monthly filing only counts goods sold to other EU countries, so if you only sell services you always file quarterly.

Before you start

  • Every EU client's VAT number, validated on VIES. Do this when you first invoice them — the number has to be valid for the reverse charge to apply.
  • The total you invoiced each EU client in the quarter (the fatura-recibo amounts, rounded to the euro).

Steps

  1. Log in to the Portal das Finanças and search for "Declaração recapitulativa" (or go to Serviços → IVA → Declaração recapitulativa do IVA → Entregar declaração).
  2. Quadro 01 — your name and NIF are filled in.
  3. Quadro 02 — tick 1 (1.ª declaração) and 1B (Não) for "change of frequency". Use 2 (substituição) only to correct one you already sent.
  4. Quadro 03 — the year (campo 1) and the quarter under Trimestral (campo 3).
  5. Quadro 04 — one line per client:
    • País de destino and Prefixo — the client's country and its VAT prefix (e.g. Slovakia → SK, Germany → DE, Greece → EL).
    • N.º de identificação fiscal — the client's VAT number, without the prefix.
    • Valor — everything you invoiced that client in the quarter, in whole euros. Several invoices to the same client go in one line.
    • Indicador do tipo de operação — 5 (prestações de serviços).
  6. Quadro 05 fills itself in. Note campo 19 — the IVA return for the same quarter must show the same amount in its campo 7.
  7. Click Validar, fix anything it flags, then Submeter. Keep the comprovativo (PDF).

Afterwards: the IVA return

When you file the IVA quarterly return a month later, put the same total in campo 7 (operations listed in the declaração recapitulativa). If the numbers don't match, the AT will flag a divergence. If you ever correct the recapitulativa, submit a replacement IVA return for that quarter too.

Late or forgot one?

Submit it as soon as you notice — the portal accepts it after the deadline and marks it as late. Missing or late declarations can be fined (art. 117.º RGIT), but the fine is much lower if you regularise on your own before the AT notifies you. If several quarters are involved, it's worth asking a contabilista.

Sources