VAT on credit intermediation: what has Portugal's Tax Authority clarified?

Finanças, Coimbra (2015) · Photo: Joehawkins / Wikimedia Commons · CC BY-SA 4.0 (resized).

Portugal’s Tax Authority has clarified the criteria for applying the VAT exemption to credit intermediation services. Professionals should assess the functions actually performed.

Article 9(27)(a) of the Portuguese VAT Code exempts the granting and negotiation of credit. Circular Letter No 25122/2026, dated 21 October, explains its application to intermediation.

Example: supporting a credit application

An intermediary finds a client, helps prepare the documentation, presents offers and handles communication with credit institutions. These services may qualify for the exemption when they are directed towards concluding the credit agreement.

By contrast, filing or administrative support without a direct purpose of enabling credit agreements does not qualify for this exemption simply because the customer is a credit intermediary.

Credit managers and master networks: avoid automatic conclusions

The title “credit manager”, payment of a commission or invoicing a master network does not, by itself, determine the treatment.

Alongside the tax assessment, the rules governing the activity must be respected. Article 47 of the regime approved by Decree-Law No 81-C/2017 prohibits intermediaries from entrusting third parties, wholly or partly, with credit intermediation and advisory activities. The Tax Authority’s circular does not remove that prohibition.

What should be organised?

As an operational recommendation, keeping contracts, service descriptions and records of each provider’s involvement helps inform the legal and accounting assessment.

Official sources

• Portuguese VAT Code — Article 9(27)(a) (Portuguese).
• Tax Authority — Circular Letter No 25122/2026, dated 21 October (Portuguese).
• Regime approved by Decree-Law No 81-C/2017 — Article 47 (Portuguese).