Portugal VAT and TOMS Guide for Travel Businesses | Portuguese Tax Rules Explained
Complete overview of Portugal VAT, travel rates, TOMS margin rules, and compliance requirements for inbound and outbound operators.
Detailed VAT and TOMS guide for travel agents, tour operators, and DMCs working in Portugal. Understand VAT rates, place of supply, accommodation rules, event services, and margin calculations. Includes TOMS treatment, compliance obligations, and VAT reclaim guidance.
Portugal – VAT and TOMS for Travel Businesses
Modern VAT system introduced: 1986 (Imposto sobre o Valor Acrescentado, IVA)
Standard VAT rate: 23 percent (mainland)
Reduced rates: 13 percent and 6 percent
Regional rates: Different IVA rates apply in the Azores and Madeira
Authority: Autoridade Tributária e Aduaneira (AT)
Portugal is a major European destination for leisure travel, group tours, events, retreats, and conferences. It applies the EU Tour Operator Margin Scheme (TOMS) and operates one of the most advanced digital VAT control systems in Europe, including mandatory real-time invoice reporting and certified invoicing software.
For travel agents, tour operators, and DMCs, the main VAT risks in Portugal relate to rate differentiation between mainland and islands, principal versus agent treatment, event VAT exposure, and strict electronic invoicing compliance.
VAT treatment of travel and hospitality in Poland
Poland uses multiple VAT rates across travel services. Classification matters because the difference between 8 percent and 23 percent is material, and Poland is strict on audit evidence.
Accommodation
Hotel accommodation and similar short stay lodging is commonly subject to 8 percent VAT. This covers room charges and standard hotel services that form part of the lodging supply.
If hotels invoice separate items such as meeting room hire, business services, or premium add-ons, those items often fall under 23 percent depending on the nature of the service.
Food and beverage
Restaurant and catering services are commonly subject to 8 percent VAT, but alcohol is typically taxed at 23 percent. This split creates common leakage in group programmes and hotel packages if alcohol is included and not properly separated.
Passenger transport
Passenger transport within Poland is commonly treated as 8 percent VAT. International passenger transport may be zero rated or exempt depending on the route and the underlying EU transport rules.
Tours, guides, attractions, and experiences
Tourism experiences often sit at the 23 percent VAT rate, especially where the supply is a commercial service such as guiding, tours, sightseeing services, or event-style experiences. Some cultural services may qualify for reduced rates, but the eligibility depends on the classification of the supply and the provider, so travel businesses should not assume reduced VAT applies automatically.
DMC and event organiser fees
DMC fees, coordination fees, event management, staging, AV, and incentive programme production typically fall under 23 percent VAT unless the supply is treated under TOMS as part of a margin scheme supply.
Place of supply rules
Poland follows EU place of supply rules, which means VAT often attaches to where the service is performed or consumed.
Accommodation is taxed where the property is located, so Polish hotel stays are taxed in Poland.
Admission to events and services connected with events in Poland are taxed in Poland. This is a frequent trigger for foreign MICE organisers.
Restaurant and catering services are taxed where physically carried out.
Cultural, entertainment, and similar admission-based supplies are taxed where performed.
For foreign travel companies, this usually means Poland VAT arises whenever the itinerary includes Polish accommodation, Polish events, or Polish on-the-ground services, unless TOMS applies.
Poland and the Tour Operator Margin Scheme (TOMS)
Poland applies the EU margin scheme for travel agents. You will often see this described locally as the travel agency margin procedure, and it is used for tour operators acting as principal who buy in travel services and resell them.
When TOMS applies
TOMS applies when the operator:
• buys in travel services such as accommodation, transport, excursions, guides
• sells the trip or component in its own name as principal
• supplies travel consumed within the EU
• provides the travel service to a traveller, whether leisure or business
What is taxed
Only the margin is taxed. Input VAT on the bought-in travel components that form part of the margin scheme supply is blocked, meaning it cannot be reclaimed.
VAT rate under TOMS
The margin is taxed at Poland’s standard VAT rate of 23 percent, not at the reduced rates that may apply to the underlying components.
Non-EU travel and zero rating
Where travel takes place outside the EU, the margin can qualify for zero rating. Mixed itineraries require careful allocation between EU and non-EU travel.
Exclusions from TOMS
TOMS does not apply to:
• intermediary agency services where the travel agent earns a commission
• standalone management fees and consultancy
• event management fees charged separately from bought-in travel services
• supplies where VAT is itemised under normal rules rather than treated as a margin supply
This principal versus agent analysis is one of the biggest audit risk areas for travel businesses operating across borders.
Invoicing requirements in Poland
Poland is strict on invoice content and VAT documentation. A compliant invoice normally needs:
• supplier legal name and address
• supplier VAT number
• customer VAT number where relevant
• invoice number and issue date
• date of supply where different
• description of the service
• taxable base, VAT rate, VAT amount
• references to special procedures where applicable, including the margin scheme treatment for travel agents
Invoices under TOMS
Where TOMS applies:
• VAT is not shown as recoverable on the invoice
• the invoice must clearly indicate margin scheme treatment
• the customer should not be led to believe they can deduct VAT
Digital reporting and compliance in Poland
Poland has been one of the EU leaders in VAT digitisation.
JPK and VAT filings
Poland requires electronic VAT reporting and structured files that combine VAT return data with invoice-level detail. Travel businesses operating in Poland should expect that VAT reporting and invoice data can be cross-checked quickly by the tax authority.
Mandatory national e-invoicing through KSeF
Poland has legislated mandatory e-invoicing through the Krajowy System e-Faktur (KSeF). The current enacted timeline is:
• 1 February 2026 for large taxpayers with turnover above PLN 200 million
• 1 April 2026 for other VAT registered businesses
Travel businesses with a Polish VAT number should plan early, because KSeF changes how invoices are issued, validated, and received, and non-compliant invoices can be rejected by the system rather than merely challenged later in audit.
For DMCs, hotels, event suppliers, and tour organisers established in Poland, KSeF will become operationally critical.
VAT registration for foreign travel companies
A foreign travel company may need to register for Polish VAT if it:
• supplies taxable event services in Poland
• sells accommodation in Poland as principal
• provides catering services or other on-the-ground services taxable in Poland
• has a fixed establishment in Poland
• makes supplies outside TOMS that require Polish VAT charging
Reverse charge can apply to certain B2B services, but accommodation and event-related supplies generally remain taxable in the country where they occur, and these are the most common triggers for travel and MICE.
Non-EU businesses may need a fiscal representative depending on their status and activity.
VAT reclaim position
VAT incurred in Poland may be refundable via:
• the EU 8th Directive process for EU businesses
• the EU 13th Directive process for non-EU businesses
VAT incurred on costs linked to TOMS supplies remains non-recoverable.
For reclaim mechanics, eligibility, documentation standards, and deadlines, go to VAT Reclaim page.
Antravia helps
Antravia supports travel businesses with:
• Portugal VAT classification and regional rate analysis
• mainland vs island VAT reviews
• TOMS margin modelling for Portuguese itineraries
• SAF-T and certified invoicing readiness
• VAT registration and fixed establishment assessments
• DMC, retreat, and MICE VAT reviews
• reclaim feasibility analysis
• identifying VAT leakage across Portugal-based programmes
Not based in Portugal but looking for Portuguese VAT Reclaim? Click here
Not sure where to start? Contact Antravia for a free Consultation
Disclaimer:
Content published by Antravia is provided for informational purposes only and reflects research, industry analysis, and our professional perspective. It does not constitute legal, tax, or accounting advice. Regulations vary by jurisdiction, and individual circumstances differ. Readers should seek advice from a qualified professional before making decisions that could affect their business.
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