From now on, if your company awards a construction contract and the contractor does not hold a valid contractor's license (alvará) or construction certificate issued by the IMPIC, the VAT reverse charge rule (IVA - Autoliquidação) no longer applies. This is the change with the highest immediate impact on daily operations and company cash flow, introduced by the newly approved Housing Package (Decree-Law no. 97/2026).
Many companies became accustomed to billing repair, remodeling, or painting services with the mention "IVA - Autoliquidação," even without being formally registered construction firms. The Tax Authority put an end to this practice. For the reverse charge to occur — meaning the service provider bills without VAT and the client assumes tax assessment —, the builder MUST hold a public or private works contractor's license or certificate. If they do not, they are obliged to bill with standard VAT, forcing the entity awarding the work to pay the tax upfront.
The second major update in this legislative package is excellent news for real estate promoters and residential leasing businesses. Until now, as entities carrying out exclusively tax-exempt operations (without the right to deduct VAT), these companies always received construction invoices with tax charged upfront by the builder.
Under the new law, the reverse charge mechanism now also applies to these tax-exempt companies, but only in a very specific scenario: when contracts are intended for properties for sale (Primary Residence - HPP) or for residential lease framed under the new reduced rate, Item 2.42. In practice, this means the work must respect strict "moderate value" limits, such as charging rents that do not exceed €2,300 per month in 2026.
If your residential leasing company awards one of these eligible contracts:
- The builder (holding the respective IMPIC license) issues the invoice without VAT, stating "IVA - Autoliquidação".
- Your company, despite not carrying out VAT-taxable activities, must submit a periodic VAT return by the end of the following month to declare and pay this self-assessed tax to the State.
- The major financial advantage is that this tax is self-assessed directly at the new reduced rate applicable under Item 2.42, drastically lowering the net cost of the construction work.
These rules formally enter into force on July 1, 2026, but can be applied with retroactive effect to invoices issued since January 1, 2026, provided there is mutual agreement between the contractor and the client. As these new rules intersect real estate price caps with formal licensing requirements, an improper reverse charge can be costly in fines and compensatory interest.










