How to prepare Form 39 (Modelo 39, capital income)

What is it for?

Form 39 (Modelo 39) is the annual return of capital income paid to resident individuals, with withholding at the final rate (taxa liberatória). In practice, it is the interest the company pays to a shareholder or to someone who lent it money, with 28 % withholding.

This procedure generates the file to submit on the Portal das Finanças. The product sends nothing to the Tax and Customs Authority (AT). Pending validation by a certified accountant: filing deadline and income covered.

When to use it?

• At the start of each year, to declare the interest paid in the previous year.
• When the company pays interest on shareholder loans to a shareholder or interest on a loan to a resident individual.
• When you submitted the return with errors and have to replace it.
• Do not use it for income whose withholding is not final, such as rents or fees: those go in Form 10. Companies and non-residents are not included in this file either.

Where to find it?

Accounting › Declare › Withholding tax › What is there to do with the withholdings? › Supporting lists › Modelo 39 file.

Before you start

• Your profile is Certified accountant. The Accountant does not have this link on the dashboard, nor the Modelo 39 income codes one.
• The interest is entered on confirmed supplier invoices, for the year to declare. See step 1.
• You have the number of your Tax office, with 4 digits.

How to use it

1. On the supplier invoice for the interest, the line carries the tax Retenção IRS 28% — rendimentos de capitais (taxa liberatória) (IRS withholding 28%, capital income, final rate) and the VAT tax the certified accountant tells you. After choosing the withholding, in Nature of the capital income, choose Interest on shareholder loans or Interest on loans. Confirm the invoice.
2. Open Accounting › Declare › Withholding tax › What is there to do with the withholdings?. Under Supporting lists, click Modelo 39 file.
3. In Year, type the year to declare, for example 2026. The window opens with the year before the current one.
4. Type the Tax office, for example 3085.
5. If the certified accountant signs the return, type the NIF of the Certified Accountant.
6. In Type of declaration, choose First declaration or Replacement.
7. Click Download the file of the AT.
8. Submit the file on the Portal das Finanças. You do the submission yourself, outside the product.

Expected result

The file MODELO39_<NIF of the company>_<year>.xml is downloaded, for example MODELO39_509999999_2026.xml. It has one line per holder and per income code.

In the example, the line has the shareholder's tax number 123456789, code 03, income of €1,000.00 and an amount withheld of €280.00. In the file, amounts are in cents: 100000 and 28000. Interest on shareholder loans gives code 03 and Interest on loans gives code 19.

The example supplier invoice generates these lines. Generating the file creates no journal entries.

Account	Debit	Credit
6911 Juros de financiamentos obtidos	€1,000.00
242 Retenção de impostos sobre rendimentos		€280.00
2211 Fornecedores gerais		€720.00

Important notes

• The file only sees confirmed supplier invoices, with the final-rate withholding, with the nature filled in and from a resident individual. An invoice without a nature is left out without warning: check the file total against account 242 for the year. An invoice not yet paid is also included. Pending validation by a certified accountant: the moment at which the income counts.
• The product recognises an individual by the tax number (NIF), which starts with 1, 2 or 3. Without a tax number, it uses the company flag on the contact form.
• The file is always generated afresh from the invoices, so it is not stored in the product. Keep it with the proof of submission.

Common problems

“The file of the Modelo 39 2025 cannot be generated. What happened: O ficheiro do Modelo 39 não é válido: Quadro 4: falta o serviço de finanças (4 algarismos). | Quadro 6: não há rendimentos a declarar. How to fix it: correct what is listed (tax office, tax numbers, income codes).” (the file is not valid: Table 4: the tax office is missing (4 digits); Table 6: there is no income to declare). Both may be missing. Type the Tax office. Then check the Year, which opens on the previous year.

“Quadro 6: não há rendimentos a declarar” (no income to declare) still appears. There are no invoices for that year meeting the conditions above. Open the supplier invoice and check the withholding, the Nature of the capital income and the state. If the invoice is from a company or a non-resident, it is not included in Form 39.

When confirming the invoice: “Line "Juros de suprimentos 2026" of the invoice to Sócio (suprimentos) has no VAT tax. Choose a VAT tax (or a 0% VAT tax with an exemption reason, or a "not subject" tax).” The withholding does not replace the VAT tax. Add to the line the VAT tax the certified accountant tells you.

The Nature of the capital income field does not appear. It only appears when the line has the capital income withholding. Choose the withholding first.