Inês is a designer and just landed her first client abroad: an agency in Berlin. She did everything right on the invoice - asked for the client’s EU VAT number, charged no IVA, and added the reverse-charge note. She felt like a pro.
What Inês doesn’t know is that the invoice was only half the job. Because she’s in the standard VAT regime and invoiced a business in another EU country, she picked up a second obligation: sending the tax authority a list of those operations, at the rhythm of her VAT filing — quarterly, in her case. It’s called the recapitulative statement (declaração recapitulativa), and it’s one of the duties that most often slips past people who start invoicing abroad.
What the recapitulative statement is
The recapitulative statement is an information return - you pay no tax by filing it. Its only job is to tell the AT (the Portuguese tax authority) “I invoiced these operations to these clients in other EU countries”.
Why? Because when you invoice a business in another Member State, you don’t charge IVA (the client self-assesses it in their own country - so-called reverse charge). The recapitulative statement is the piece that lets the tax administrations of the different countries cross-check that information: the AT knows what you declared, and the client’s country confirms that they self-assessed the IVA on their end.
The legal basis: for services (the freelancer’s case), the obligation comes from art. 29.º n.º 1 i) of the CIVA; for goods, from art. 23.º n.º 1 of the RITI. The deadlines are in art. 30.º of the RITI.
Who files it - and what goes on it
If you invoice services to businesses (taxable persons with a valid VAT number) in other EU countries and you’re in the standard VAT regime, you have to file it. And there’s no minimum: even a single invoice a year triggers it.
And if you’re exempt under art. 53.º? Good news: since the March 2025 changes to the VAT Code, you’re excused from the recapitulative statement. Art. 59.º waives the code’s remaining obligations for exempt freelancers - including this one, as the tax authority clarified in Circular Letter (Ofício Circulado) no. 25062/2025, point 28. If you leave the exemption, the obligation arrives with the standard regime.
What goes on the statement:
Notice the difference that decides almost everything: this is only for clients that are businesses. If you invoice final consumers (private individuals) in another EU country, the recapitulative statement doesn’t concern you - that’s a different story, the One-Stop Shop (OSS). For the typical freelancer, what fills the statement is B2B services.
Warning: always confirm that the foreign client really is a business and that their VAT number is valid - check it in VIES before you invoice. A foreign freelancer or self-employed professional counts, in practice, as a business for this purpose. If you treat a business client as if they were a private individual, you invoice incorrectly and leave yourself out of the statement when you should be in it. Ask for the EU VAT number right at the start - see how to ask your European client for it.
When you file: monthly or quarterly
The rhythm of the statement follows, in principle, your IVA status:
- Quarterly regime (most freelancers): you file by the 20th of the month following the end of the quarter.
- Monthly regime: you file every month, by the 20th of the following month.
There’s an exception, but it almost only catches those who sell goods (not services): if your transfers of goods to the EU exceed €50,000 in the current quarter or in any of the four previous quarters, you’re compelled to file the statement every month (art. 30.º n.º 2 of the RITI). Since this threshold counts goods only, anyone invoicing services keeps the rhythm of their VAT filing - quarterly for most freelancers.
And, unlike the IVA return, if in a given quarter you had no intra-EU operations, you don’t file a recapitulative statement for that period - there’s simply nothing to list.
How it links to VIES and the client’s reverse charge
It’s worth understanding the mechanism, because it’s what explains why you can’t forget it.
When you file the statement, the AT feeds the VIES (the EU’s VAT Information Exchange System). From there, the tax authority in your client’s country sees that you declared a sale to them. On the other side, the client self-assessed the IVA on their own return. The two ends have to match - it’s a mirror operation.
- Invoice with no IVA (reverse charge)
- File the recapitulative statement
- Pay no IVA on this operation
- Receives the invoice with no IVA
- Self-assesses IVA at their country's rate
- Deducts that IVA on the same return
This is where a lot of people get into trouble. If your intra-EU operations show up on your IVA return but have no matching recapitulative statement, a flag goes up - and an inspection can grow from there.
Example: Tiago and the Madrid agency
Tiago is a developer and invoiced €4,000 to an agency in Spain over the first quarter (January to March). He issued everything with reverse charge, no IVA. His sequence is this:
- Before the first invoice: he confirmed the agency’s VAT number in VIES and activated his own NIF for intra-EU operations.
- When invoicing: each receipt went out with no IVA, carrying the note “IVA - Autoliquidação”.
- By 20 April: he filed the recapitulative statement for Q1, listing the Spanish agency, its VAT number, and the €4,000.
Notice a calendar detail: the Q1 recapitulative statement is due on 20 April, but the quarterly IVA return is only filed later (as a rule, the 20th of the 2nd month after the quarter). In other words, the recapitulative statement usually falls earlier - don’t rely on the IVA return deadline to remind you of it.
And don’t confuse this statement with the reverse charge you pay when you’re the buyer of foreign services (Google, Meta, Upwork ads): that’s the other side of the coin, and we explained it in reverse charge: the Google and Meta invoices that make you pay IVA. The recapitulative statement is about what you sell to EU businesses.
✅ In summary
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Invoiced services to a business in another EU country under the standard VAT regime? On top of invoicing with no IVA (reverse charge), you must file the recapitulative statement - an information list of those operations, with no tax to pay. There’s no minimum: one invoice is enough. Freelancers exempt under art. 53.º have been excused since March 2025.
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The rhythm follows your VAT filing: quarterly filers submit by the 20th of the month after the quarter ends (earlier than the IVA return); monthly filers submit every month. Selling goods above €50,000 forces the monthly rhythm. With no operations in a period, you file nothing.
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With FIZ this stops being a trap: the software spots the invoices to EU businesses, applies the reverse charge, and handles the recapitulative statement on time - see how FIZ handles the recapitulative statement for you. Also see the plans.
