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Regulation explainer

How to invoice your Airbnb and Booking.com guests in Portugal (without the headache)

Invoice the guest, not the platform — and almost always on the payment date, not '5 days later'. 6% VAT, the €15,000 article-53 exemption, guests without a NIF and reporting to the tax authority, with sources.

Invoicing is where host coffee-table wisdom diverges furthest from the law: "the platform handles it", "only if the guest asks", "I have five days". None of the three is true — and the three together explain most of the nasty surprises. Let's put the rules in order, sources in plain sight.

Who you invoice: the guest, not the platform

The accommodation service is provided by you to the guest — Airbnb and Booking are intermediaries. That's why the invoice is issued to the guest, for every stay, whether or not they ask for it: article 29 of the VAT Code requires issuance "regardless of the status of the acquirer […] even if they do not request it". The tax authority (AT) has confirmed this specifically for alojamento local in binding rulings.

And the commissions exception? With commissions it's the reverse: there you're the customer, and the platform invoices you. Those invoices carry two tax tails that many hosts discover late: the VAT is self-assessed in Portugal (even if you're exempt under article 53 — the AT has said this in writing too), and payments to the platforms trigger a declaration of their own, Modelo 30 — we've explained it all here.

When to issue: almost always on the payment date

The rule everyone quotes is the "5th working day" (article 36(1) of the VAT Code). The rule almost nobody quotes sits two lines below: for advance payments, the invoice is issued on the date of receipt (paragraph c). Since the overwhelming majority of AL bookings are paid before the stay, your practical reality is:

  • Guest paid in advance (the norm on Airbnb/Booking): invoice on the date you receive the payment;
  • Payment at check-out: fatura-recibo on the spot, or an invoice by the 5th working day after the service.

On the Portal das Finanças, the fatura-recibo is for when the operation and the payment coincide; for advance payments, issue on the date of the advance.

Foreign guest without a NIF: what goes on the document

For final consumers, the acquirer's NIF is not mandatory — it only becomes so "when they request it" (article 36(16) of the VAT Code). A foreign guest without a Portuguese NIF doesn't stop you invoicing: you issue to a final consumer, identifying the customer the way your software provides for. The AT's official guidance on foreign guests specifically is thin — if in doubt about the exact fields in your invoicing software, it's worth one question to your accountant; the legal principle is as above.

VAT: 6%, and the €15,000 exemption

Two possible situations, and you should know which one you're in:

  • With VAT: accommodation in hotel-type establishments — which includes AL — sits in item 2.17 of List I: the reduced rate of 6% on the mainland (in the autonomous regions the lower regional reduced rate applies). The reduced rate covers accommodation and breakfast not invoiced separately.
  • Exempt (article 53): if in the previous calendar year you didn't exceed €15,000 of turnover in Portugal, you may qualify for the exemption — a regime rewritten by Decree-Law no. 35/2025 (in force since July 2025). Mind the exit rules: exceeding the threshold by more than 25% forces an immediate exit. And the exemption does not excuse you from issuing invoices, from reporting them to the AT, or from self-assessing VAT on the platform commissions.

If you're weighing exemption vs. the normal regime (or simplified vs. organised accounting for IRS), our simplified-regime article helps sort the pieces — with your accountant closing the decision.

Reporting to the AT: the invoice isn't done when you issue it

Every issued invoice must reach the AT by the 5th of the following month (Decree-Law no. 198/2012, article 3) — via webservice, SAF-T (PT) file, or manual entry on the portal. If you invoice on the Portal das Finanças this is handled by definition; if you use your own software, you need to ensure the reporting happens. Since 2023, the ATCUD is mandatory on tax documents, and the QR code accompanies invoices from certified software.

Invoicing at scale: where this starts to hurt

One invoice per stay, on the date of each payment, reported by the 5th, to the right guest with the right tax treatment — times 4, 8, 15 properties. It's the same pattern we described when Excel stops being enough: not a hard task, a relentless one.

That's why ALerta integrates with InvoiceXpress: reservations come in, invoices go out with the right data on the right date, and the AT reporting follows on its own. Join the waitlist and turn invoicing into what it should be — an automatic by-product of your reservations, not a second job.

Sources