Beatriz is a clinical psychologist; Rita, also a psychologist, mostly does coaching and well-being workshops for companies. Both assume “health is VAT-exempt”. One is right; the other will have to charge 23% - and the line between them is the therapeutic purpose.
Health is exempt - by the service, not the profession
The art. 9.º CIVA exemption covers health services with a therapeutic purpose provided by medical and paramedical professions. Beatriz’s clinical psychology session fits here: she issues receipts without VAT. The same goes for physiotherapists, speech therapists and the like - paramedical activity with a health purpose.
The key point: the exemption is by the service, not the whole profession. Being a psychologist doesn’t exempt everything Beatriz does - it exempts the clinical act.
What’s left out: coaching, well-being, companies
That’s where Rita trips up. Coaching, well-being workshops, training or consulting for companies have no therapeutic purpose - so they aren’t exempt under art. 9.º and carry 23% VAT (unless she fits the art. 53.º exemption, invoicing up to €15,000/year in Portuguese territory).
Doing both? You have to separate them
If, like Rita, you mix clinical sessions (exempt) with coaching (taxed), you can’t lump it all together: you have to separate the two activities and, on the VAT you pay on your purchases, apply partial deduction (by real allocation or pro rata, art. 23.º of the CIVA). It’s worth checking the calculation before you submit.
The exemption is “incomplete”
Watch one detail: the art. 9.º exemption does not give you back the VAT on your purchases. The VAT on materials, software or your practice’s rent, on the exempt share, is a cost you don’t recover (art. 20.º of the CIVA). It’s not “VAT at 0%”, it’s an exemption.
The rest: your professional body, code and Social Security
As a psychologist you need a professional licence from the Ordem dos Psicólogos Portugueses. Otherwise, you’re a self-employed worker like any other: you open activity with your code, and Social Security is 21.4% on 70% of what you invoice.
Careful: the costly mistake is assuming “I’m a psychologist, so everything I do is exempt”. The exemption is for the service with a therapeutic purpose. A coaching session or a workshop at a company generally carry VAT.
✅ In summary
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Clinical psychology sessions are exempt under art. 9.º (reason M07) - but only when they are a clinical act by a recognised health professional (a psychologist with a cédula, physiotherapist, speech therapist), not the whole profession nor a mere “therapeutic purpose”. Coaching, well-being and company training generally carry 23%.
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If you mix the two, separate the activities and apply partial deduction of the VAT on purchases. And remember: the art. 9.º exemption is incomplete - you don’t deduct the VAT on purchases tied to the exempt part.
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With FIZ you issue each receipt with the right treatment - exempt (art. 9.º or 53.º) or with 23% - and VAT and Social Security are handled for you, no article-memorising required. See the plans.
