What Digital Trainers and Consultants Need to Know in 2025
Published by GoalSeek | March 2025
Author: Rui Borges, CPA 84392, Senior Tax Consultant at GoalSeek
As of March 24, 2025, Portugal has implemented Decree-Law No. 33/2025, updating VAT rules for digital service providers — especially for professionals offering online training, webinars, streaming content, and similar virtual services. The changes bring Portuguese VAT law in line with EU Directive 2022/542 and aim to clarify where VAT applies depending on your client’s location and status.
If you’re a trainer, coach, or freelancer in Portugal selling services online, this article will help you determine when and how to charge VAT.
🔍 Key Definitions
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B2B: Business-to-business (client has a valid VAT number)
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B2C: Business-to-consumer (private individuals with no VAT registration)
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Digital services: Virtual training, live-streaming events, downloadable content, online memberships, etc.
1. If Your Client Is a Business (B2B)
📌 Rule: VAT applies in the client’s country (Article 6, no. 6, a) of the VAT Code).
âś… Implication: You do not charge Portuguese VAT for foreign B2B clients.
💡 Example: You sell an online course to a registered company in Germany. → No Portuguese VAT.
📄 Invoice note: “VAT reverse-charged under Article 6 of the Portuguese VAT Code.”
2. If Your Client Is a Private Individual (B2C)
a) Client Outside the EU (e.g., USA, Brazil)
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General rule: No Portuguese VAT.
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Exception: VAT applies if the service is used or effectively consumed in Portugal.
💡 Example: A Brazilian client accesses your online course while vacationing in Portugal. → VAT applies.
b) Client in the EU (e.g., Spain, France)
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General rule: VAT is due in the client’s country.
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Optional rule: If the service is used in Portugal, Portuguese VAT may apply under the “effective use” rule.
💡 Example: A Spanish customer accesses your course while physically in Portugal → VAT may apply.
3. What Is “Effective Use or Enjoyment”?
According to Article 6, no. 14, the service is deemed to be used in Portugal when:
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Access is through Portuguese internet networks (e.g., hotels, cafés)
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The device uses a Portuguese IP address or SIM card
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The client is physically present in Portugal
đź’Ľ Summary Table for Freelancers
| Client Type | Client Location | Charge PT VAT? | Reason |
|---|---|---|---|
| Business | In Portugal | Yes | Local rule (Art. 6.Âş, no. 6) |
| Business | Outside Portugal | No | Reverse charge applies |
| Individual | In Portugal | Yes | Domestic supply |
| Individual | EU (outside PT) | No (default) / Yes (if used in PT) | Use rule (Art. 6.Âş, no. 12) |
| Individual | Outside EU | No (default) / Yes (if used in PT) | Use rule (Art. 6.Âş, no. 12) |
✅ GoalSeek’s Recommendation
As a freelancer based in Portugal, you must:
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Determine if your client is VAT-registered
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Check where the client is located and where the service is used
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Keep documentation of client location (e.g., billing address, IP logs)
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Add the correct VAT note to your invoices
When in doubt, seek professional VAT advice to avoid penalties and ensure compliance — especially when dealing with clients abroad.
đź“Ś Need Help?
At GoalSeek, we support freelancers and digital entrepreneurs in structuring their activity for tax efficiency — including VAT compliance, international invoicing, and digital service rules.
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