How to Pay Non-VAT Registered Influencers in Portugal: A Clear, Legally Coherent Guide for Brands, Agencies & UGC Platforms (2026)

The creator economy in Portugal is booming. Brands now work heavily with micro-influencers, UGC creators and affiliates—many of whom are not registered as self-employed (trabalhadores independentes).

This creates a recurring question:

“How can we legally pay a Portuguese creator who isn’t registered as self-employed, without creating tax complexity or friction?”

This article explains—clearly, accurately and with respect for Portuguese tax rules—

How payments work, what options exist, and how Zexel Pay fits into a compliant, operationally efficient model.

The Basic Framework: When Does a Portuguese Creator Need to Register as Self-Employed?

Portuguese tax law is clear:

A creator must register as a trabalhador independente when their activity is:

  • regular,

  • organised,

  • recurring,

  • or economically significant.

Register as a Freelancer: Declare your activity by completing the ‘Início de Atividade’ form under the “Category B” income bracket on Portal das Finanças. This step is essential to operate legally and issue valid invoices. Ensure you provide accurate information about your type of work and expected income.

 

For genuinely occasional collaborations, Portugal allows the use of the:

Ato Isolado (Isolated Act)

A legal mechanism that allows issuing a single receipt for a non-habitual activity without opening a continuous business activity.

Important notes:

  • It applies only to occasional work.

  • It does not replace the obligation to register if activity becomes recurrent.

  • It does not become a income higher than the year salary in Portugal.

  • It may involve VAT (IVA) and social security contributions depending on income.

What if the Creator Does NOT Want — or Is Not Ready — to Issue an Ato Isolado?

This is common in UGC and micro-influencer campaigns not only in Portugal but in Europe:

  • low payments,

  • little to no fiscal experience,

  • sporadic collaborations,

  • informal activity not yet a “business”,

  • concerns about Social Security obligations.

Brands often do not want to manage direct payments to individuals without invoices, nor deal with Portuguese withholding obligations.

This is where the intermediated payment model, used by global platforms, becomes relevant.

What Zexel Pay Is — and Is Not

Zexel Pay is a Spanish or Estonia-based account payable software that also offer vendor outsourced services solutions.

Zexel Pay is not a replacement for the creator’s tax obligations.

Zexel Pay does not declare taxes on behalf of creators.

Zexel Pay does not claim that someone can receive income indefinitely without becoming self-employed.

What Is Accounts Payable Outsourcing?

While many tools automate parts of the payout process, Accounts Payable Outsourcing (APO) goes further.

It means the provider handles the entire operation, including:

  • Checking, correcting, and validating invoices

  • Ensuring creators meet fiscal requirements

  • Sending payouts

  • Preparing documentation for accounting

  • Handling communication with creators

  • Monitoring compliance

  • Operating as your extended finance team

This is crucial for agencies with small finance teams or platforms that manage hundreds of creators.

From a Portuguese Tax Advisor’s Perspective: Why This Model Is Coherent

The key distinction is simple:

👉 When a creator provides a direct professional service, they must issue an invoice (Ato Isolado or as a registered independent worker).

👉 When the creator participates in an intermediated system, there is no direct service relationship with the paying brand.

Therefore:

  • No Portuguese VAT applies on the creator side.

  • No IRS withholding is required from the brand.

  • The brand has no fiscal obligations in Portugal, because its supplier is Zexel Pay (Spain).

  • The creator receives funds as platform-mediated income, not a professional service invoice.

This is fully aligned with how:

  • TikTok Shop,

  • Amazon Associates,

  • affiliate networks that offers payout outsourcing,

  • creator monetisation apps operate across Europe.

Important clarification:

➡ The creator’s personal tax responsibility remains intact.

They should and must declare income if and when their individual fiscal situation requires. But this is their responsibility.

The Creator’s Responsibility — Explained Clearly

Zexel Pay maintains full transparency:

✔ Zexel Pay can facilitate your payments in a simple way.

✔ But if your activity becomes regular, you are running a business.

And then:

Zexel Pay does not decide when this moment arrives—it is the creator’s legal responsibility.

When a creator decides to professionalise their activity, the creator can update their profile and upload invoices or use Zexel Pay Invoice creator system.

Why Companies Prefer Using Zexel Pay

For brands, agencies and UGC platforms

  • One supplier → one invoice → one payment.

  • No Portuguese tax risk or withholding obligations.

  • Eliminates operational friction with creators.

  • Full payout automation.

For creators

  • They get paid smoothly in early collaborations.

  • They can receive funds in their own currency or account.

  • They have traceable documentation.

  • They can professionalise later when it makes sense.

For accountants and advisors

  • The model does not avoid fiscal obligations.

  • The brand is not paying a Portuguese individual.

  • The creator’s tax responsibility remains intact.

  • The structure mirrors widely accepted EU platforms.

Zexel Pay (Hybrid Software + Outsourcing)

 

Zexel Pay is built to make it easy to outsource affiliate, UGC, and creator payouts.

You can:

  • Start with a simple CSV upload for mass payouts
  • Or go deeper with API integration
  • Get 1 consolidated invoice per cycle (even with 200+ creators)
  • Stay compliant with EU tax laws and local regulations
  • White-label the payout experience to match your platform

Accounts Payable Software (Without Outsourcing)

Some tools help automate payments but do NOT take care of the manual work or compliance:

Stripe

  • World-class payment infrastructure

  • No vendor  invoice validation

  • Not designed for creator payouts niche

Tipalti

  • Very powerful enterprise tool

  • Expensive and complex

  • Requires internal AP team

  • Not tailored for influencer/creator workflows

PayPal Mass Payouts

  • Great for quick global transfers

  • No tax validation

  • No invoice control

  • No consolidated billing

These solutions automate payments, but they do not solve the operational burden.

Who Needs a Creator Payout Service?

The ideal users include:

  • Creator agencies

  • Influencer marketing platforms (e.g., Cruwi, Influencity)

  • UGC production platforms

  • Affiliate networks (Monetize, CJ, Awin, Impact)

  • Brands using affiliate software without payout modules

  • Marketplaces and apps managing creators at scale

If your team spends hours chasing invoices, fixing fiscal data, or uploading payments manually — this service is for you.

 

Questions You Must Ask Before Choosing a Payout Solution (and the Real Answers)

What information does Zexel Pay need from creators?

Only the minimum required for:

  • KYC/KYB compliance,

  • AML regulations,

  • platform payout safety,

  • and DAC7 reporting (when applicable).

The required data:

Profile information

  • Full name

  • Email address

Fiscal identification

  • Tax Identification Number (NIF or equivalent)

  • Current fiscal residence address

Banking information

  • Bank account where the creator is the verified account holder

  • Alternative payout methods when legally permitted

We do not request more information than necessary.

Does Zexel Pay report DAC7?

Yes.

When a creator’s activity falls under the scope of DAC7 (EU platform reporting), Zexel Pay collects and reports the required information to tax authorities.

DAC7 does not create additional tax liability.

It simply enables automatic information exchange between EU countries.

 

Does the solution support non-freelancer creators legally and compliantly?

Yes — Zexel Pay does.

Most tools only work with freelancers.

Zexel Pay is one of the few solutions in Europe that legally supports non-self-employed creators, handling IRPF, fiscal verification, and all required local compliance.

Most generic payout tools = ❌ no legal coverage.

Zexel Pay = ✅ full compliance for autónomos + non-autónomos.

Can it consolidate hundreds of invoices into one invoice?

Yes — Zexel Pay consolidates everything into a single invoice per cycle.

This is essential for finance teams.

Tools like PayPal, Stripe, or Tipalti do not consolidate creator invoices — leaving your team with hundreds of documents to reconcile manually.

Zexel Pay = 1 invoice for all creators, all campaigns, all payouts.

Does it handle global payouts in multiple currencies?

Yes — Zexel Pay supports creator payouts in 180+ countries and multiple currencies, while you receive one invoice with one currency .

Affiliate networks, influencer agencies, and UGC platforms increasingly work with creators worldwide.

Stripe/PayPal handle payments, but do not solve invoice validation or creator verification across borders.

Zexel Pay = payments + compliance + global coverage.

Is it software only, or does it also offer outsourced operations?

Zexel Pay is a hybrid: software + fully managed operations.

Unlike tools where your team still has to:

  • chase invoices

  • fix tax errors

  • validate creator data

  • filter duplicates

  • explain compliance rules

Zexel Pay manages all of this for you.

Your team focuses on revenue, not admin work.

An Ato Isolado only applies when a Portuguese individual is providing a direct professional service to a specific client.

The Portuguese tax authority describes ato isolado as:

  • a non-habitual economic activity,

  • performed directly between the individual and the paying client,

  • where the individual is considered to be providing a professional service or sale of goods.

That means:

👉 It only applies if the creator is acting as a service provider.

👉 It requires identifying both parties (supplier ↔ client).

👉 It is treated as a service transaction, not a platform payout.

❌

A Portuguese no vat register creator cannot issue an Ato Isolado to Zexel Pay for platform-mediated payouts.

Why?

Because the creator is NOT providing a direct professional service to Zexel Pay.

In your model:

  • The brand or platform is the one financing the campaign.

  • Zexel Pay is a payment intermediary, not the “client” receiving UGC, content or advertising work.

  • The creator is not selling a service to Zexel Pay.

  • Zexel Pay does not use the creator’s content, nor commissions the work.

  • Zexel Pay only handles fund transfers after receiving funds from the brand.

Therefore, the legal conditions for an Ato Isolado do not exist.

If a Portuguese creator issued an Ato Isolado to Zexel Pay, it would be:

  • incorrect, because the service was not performed for Zexel Pay,

  • misaligned with how Portuguese tax authorities define a taxable service,

  • incoherent with marketplace-style payouts (Amazon, TikTok Shop, affiliate networks, etc).

⚠️ If the creator were working directly for the brand (not through Zexel Pay), then yes — an Ato Isolado might apply.

Example where an Ato Isolado would apply:

A brand in Spain hires a Portuguese influencer directly to perform a one-off service (UGC video, post, etc).

Then the creator must:

  • Issue an Ato Isolado directly to the brand (not to Zexel Pay).

  • Charge Portuguese VAT if applicable.

  • Potentially trigger Portuguese Social Security if thresholds are exceeded.

This only applies when the creator is directly contracted to perform a service.

✅ In the Zexel Pay model, the creator receives a platform-intermediated payout, not a professional service fee.

This aligns with:

  • Amazon Affiliate payouts

  • TikTok Creator Fund

  • Marketplace commission payouts

  • Referral/affiliate network payouts

In these systems, the creator:

  • does not invoice the platform,

  • does not issue recibos verdes,

  • does not issue ato isolado,

  • does not treat the platform as a “client”.

The platform is simply distributing funds, not buying services.

🔍 Does the creator still have personal tax responsibility? Yes.

Even without an invoice, the creator must:

  • declare the income if/when Portuguese tax law requires,

  • register as self-employed if activity becomes regular or economically meaningful,

  • comply with VAT and Social Security once they professionalize.

Want to explore a Zexel Pay partnership?

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