Portugal: Details on the QR Code and UUID Expected

Gabriel Pezzato
August 12, 2020

In February last year, the Portuguese government published the Law Decree 28/2019 rolling out changes affecting e-invoices. The goal of the Law Decree is to simplify and consolidate pieces of law that are scattered around the Portuguese legal framework. However, the effectiveness of many of those rules is still dependent on further regulation, such as the definition of legal and technical specifications guiding the creation of a QR code and unique identification number (UUID) that should be used on e-invoices.

What’s missing?

The deadline set hasn’t been changed by the Portuguese tax authorities in respect of the QR code and UUID, and officially remains from 1 January 2020. However, the lack of more detailed information regarding the two requirements has caused doubts that taxpayers will be able to comply with the rules before additional details have been published by the tax authorities.

According to the preamble of the Law Decree, the application of a QR code and the use of UUID on invoices are meant to simplify the communication of invoice data to the tax authorities by natural persons during the calculation of expenses deductible from income tax. The lack of specifications of the two requirements also creates room for questions as to whether all e-invoices should comply with such requirements or only invoices issued in B2C transactions.  Since in Portugal there are few differences between B2B and B2C invoices, the rules will likely apply without distinction.

What can we expect?

The Law Decree does provide clues on what to expect from future regulations around the QR code and the UUID. It sets forth that taxpayers should communicate the serial number used during the issuance of e-invoices before starting using such series. It also states that for each document series communicated to the tax authority, a code that “integrates” the UUID will be created by the tax authority. Consequently, the serial number and the UUID may be somehow associated.

When it comes to the QR code, its content will likely mirror the invoice data along with the UUID. An amendment to the income tax legislation suggests that individuals can use either the QR code or the UUID to communicate invoice data to the tax authorities when such documents are used for tax deductions.

During the last couple of months, measures taken by the Portuguese tax authorities have focused on the fight against the effects of the COVID-19 pandemic, which might have delayed e-invoicing related actions. Nevertheless, whilst in early July the Portuguese Secretary of Fiscal Affairs published a ministerial order postponing some of the obligations stemming from the Law Decree 28/2019, he remained silent about enforcing the QR code and the UUID obligations. This might be an indicator that the Portuguese government is back on track to effectively implement the measures published last year, and that the much-needed guidance will soon be published.

Take Action

To keep up to date with the changing VAT compliance landscape, download Trends: Continuous Global VAT Compliance and follow us on LinkedIn and Twitter to stay ahead of regulatory news and other updates.

Sign up for Email Updates

Stay up to date with the latest tax and compliance updates that may impact your business.


Gabriel Pezzato

Gabriel Pezzato is a Regulatory Counsel at Sovos. Based in Stockholm and originally from Brazil, Gabriel’s background is in tax, corporate and administrative law. Gabriel earned a Law degree and a specialization degree in Tax Law in his home country and has a master’s degree in International and European Tax Law from Uppsala University (Sweden).
Share This Post

LATAM VAT & Fiscal Reporting
May 20, 2020
Sovos Acquires Taxweb, Extends Tax Determination Capabilities in World’s Most Challenging Compliance Landscape

Earlier this month Sovos announced its second acquisition of 2020, completing our solution for Brazil with an unparalleled offering that solves tax compliance in the place where it is most challenging to do so.  Too many companies doing business in Brazil have been burdened by managing multiple point solutions for continuous transaction controls (CTCs), tax […]

September 24, 2020
Ask Alex: Your Bev Alc Compliance Questions Answered (September 2020)

Do you have questions about the rules, regulations, and compliance requirements of the beverage alcohol industry? This series, Ask Alex, is a perfect opportunity to get those pressing questions answered straight from one of the industry’s regulation and market experts, Alex Koral, Senior Regulation Counsel, Sovos ShipCompliant.  To take advantage of this opportunity and get […]

EMEA VAT & Fiscal Reporting
September 24, 2020
Oman to Introduce VAT

Oman is on its way to introduce VAT. After the approval of the State Council and the Shura Council the draft law was sent for final approval to Sultan Haitham Bin Tariq Al Said. If the draft law is approved, VAT is expected to be implemented in 2022. Background Gulf Cooperation Council (GCC) member states […]

EMEA VAT & Fiscal Reporting
September 23, 2020
Three Key Reasons to Appoint a VAT Compliance Managed Service Provider

With a VAT gap across EU countries estimated at €140 billion in 2018, tax authorities are continuing to take steps to boost revenues, increase efficiency and reduce fraud.  As a result, VAT compliance obligations are becoming more demanding and failure to comply can not only result in significant fines but also reputational damage. Many multinational […]

Tax Compliance Tax Information Reporting United States
September 22, 2020
2020 GCS Speaker Spotlight Series | KPMG & Zions Bancorporation

Sovos’ Global Compliance Summit – Intelligent Reporting “Speaker Spotlight” Series kicks off with the introduction to two brilliant women in the world of tax, Kelli Wooten of KPMG LLP and Susie Jensen of Zions Bancorporation, who will be attending & presenting at our upcoming conference in early October. These two professionals are particularly well-versed in […]

September 22, 2020
The Benefits of Insurtech to Captive Insurers

Tax filing, wherever you are in the world, is becoming increasingly complex, with regular rate updates and governments eager to close tax gaps via new mandates that demand real-time reporting. Despite this, many captive insurers still rely on resource-heavy, manual procedures to capture, validate and process large volumes of data. As well as taking significant […]