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Tutors and trainers: VAT exemption and the DGERT

Giving tutoring or training? One of the two is VAT-exempt under art. 9.º, the other charges 23% - and the difference is a certification (DGERT), not your CCP.

Tutors and trainers: VAT exemption and the DGERT

Ana gives maths tutoring to secondary-school students. Rui delivers Excel training to companies. Both assume “teaching is VAT-exempt”. One is right; the other is in for a surprise - and the difference isn’t in what they know, it’s in a certification.

Art. 9.º exempts teaching - but not all of it

The art. 9.º CIVA exemption covers teaching and tutoring of school subjects. Ana, who teaches curriculum material, issues green receipts without VAT - exempt under art. 9.º.

The catch is vocational training. Here the exemption doesn’t belong to the person delivering it - it belongs to the training body recognised as competent, which in practice means DGERT-certified. A CCP (pedagogical competence certificate) is a qualification of yours, not a certification of your activity.

Exempt or not?
Tutoring of curriculum subjects (Ana)
VAT-exempt under art. 9.º. You issue receipts without VAT (reason M07).
Training by a DGERT-certified body
VAT-exempt under art. 9.º.
Solo trainer, CCP only (Rui)
NOT exempt under art. 9.º - charges 23%, unless covered by the art. 53.º exemption (invoicing up to €15,000/year).

The “incomplete exemption” trap

The art. 9.º exemption has a catch Ana needs to know: it’s incomplete. Since she charges no VAT, she also can’t deduct the VAT she pays on her purchases (computer, materials, software) - that VAT stays a cost of hers (art. 20.º of the CIVA). It’s not “VAT at 0%”, it’s an exempt operation.

Ana buys a €1,000 laptop + VAT
Laptop price €1,000
VAT (23%) she pays €230
Exempt, can't recover it - real cost €1,230

And Rui? Three routes

Rui, a solo trainer with just a CCP, has three options:

  • He invoices up to €15,000/year of turnover in Portuguese territory → he can use the art. 53.º exemption (reason M10): no VAT because he’s a small business.
  • He goes over that → he charges 23% VAT on the training.
  • The training is delivered by a DGERT-certified body → then it’s exempt under art. 9.º - but it’s the body that supplies and invoices it as exempt, not Rui putting M07 on his own invoice just for working with it.
Rui delivered €2,000 of training to a company (outside art. 9.º)
Training invoiced €2,000
VAT at 23% + €460
The company pays (and Rui hands €460 to the State) €2,460

The rest is like any freelancer

You open activity with your activity code (teaching/training), and Social Security is the usual one: 21.4% on 70% of what you invoice. The big tax decision for a tutor or trainer is really the VAT one above.

Careful: the commonest mistake is Rui’s - assuming “I deliver training, so I’m exempt”. The art. 9.º exemption belongs to the certified body, not to the trainer with a CCP. Check which hat you’re invoicing under before you decide the VAT.

✅ In summary

  1. Tutoring of school subjects = exempt under art. 9.º (reason M07). But it’s an incomplete exemption: you don’t deduct the VAT on your purchases.

  2. Vocational training is only exempt under art. 9.º when it’s a DGERT-certified body - a solo trainer with only a CCP charges 23%, unless covered by the art. 53.º exemption (up to €15,000/year).

  3. With FIZ you issue receipts with the right exemption reason (art. 9.º, art. 53.º or 23% VAT) without memorising code articles, and VAT and Social Security are handled for you. See the plans.

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