This blog explores the rules governing Portugal Insurance Premium Taxation, actually known as Stamp Duty, and the corresponding parafiscals surcharges, including applicable rates, tax liability, location of risk rules, exemptions and compliance obligations.

In Portugal, the taxation of insurance premiums is governed primarily by the Stamp Duty Act (Código do Imposto do Selo, or CIS). Insurance is exempt from VAT in Portugal, meaning Stamp Duty serves as the primary indirect tax on insurance contracts.

Beyond Stamp Duty, insurers writing business in Portugal are also subject to a range of mandatory parafiscal surcharges. These levies are collected on behalf of specific public bodies, including the fire brigade charge administered by the Autoridade Nacional de Emergência e Proteção Civil (ANEPC), the insurance and pension fund supervisor (ASF), and the national medical emergency institute (INEM). These parafiscal obligations add a layer of complexity that, whilst not unique to Portugal across the EU, France, for example, also imposes a range of parafiscal charges on insurance premiums, is nonetheless notably more extensive than in the majority of European insurance markets.

• Portugal SD tax rates vary between 3% and 9%, with the standard rate being 9%.
• There are types of insurance that are exempt from Portugal Stamp Duty, including life insurance premiums.
• The governing body responsible for administering Insurance Premium Tax in Portugal is the Portuguese Tax and Customs Authority (Autoridade Tributária e Aduaneira, or AT).
• In addition to Stamp Duty and ANPC, insurers are subject to parafiscal charges including the ASF supervisory levy and the INEM medical emergency contribution
• All Stamp Duty declarations must be filed electronically monthly, with the regional location of risk (Mainland, Azores or Madeira) reported at policy level.

What is Portugal Stamp Duty?

Portugal Insurance Premium Tax refers to the tax levied on the premiums of insurance policies covering risks located in Portugal.

This tax is applied through the mechanism of Stamp Duty (Imposto do Selo), which is the oldest tax in Portugal, tracing its origins to a Royal Decree of 1660. In its modern form, it is governed by the Stamp Duty Code (Código do Imposto do Selo, or CIS), which was substantially reformed by Law 150/99 of 11 September 1999 and has been amended on several occasions since.

The standard Stamp Duty rate on insurance is 9% of the gross premium. A reduced rate of 5% applies to certain classes, including:

• Marine and aviation insurance
• Goods in transit
• Agricultural insurance
• Personal accident insurance

A further reduced rates apply to suretyship coverage.

The taxable base is the gross premium paid by the policyholder, including policy fees and ancillary charges that form part of the premium consideration.

In addition to the tax on insurance premiums, Stamp Duty also applies to broker commissions earned in connection with insurance contracts covering Portuguese risks. Broker commissions are subject to Stamp Duty at a rate of 2%, applied to the gross commission amount. This applies where the insurance broker is established or registered in Portugal.

Where a broker and/or the insurance company is based outside Portugal, for example, in Spain or another EU member state, and the risk covered is situated in Portugal, while the commission is paid between them (i.e. outside of Portugal), the position is less straightforward. Under a strict reading of the CIS territoriality rules, commissions paid to a non-resident broker would not prima facie fall within the scope of Portuguese Stamp Duty, as the transaction does not produce effects within Portuguese territory. The Tax Office guidance issued in this subject still hide ambiguity about the taxation of such commission.

Another layer of the Portuguese Insurance Premium Taxation compliance is that Stamp Duty obligation should be split by Portuguese region (Mainland, Azores and Madeira) based on the postcodes of the associated risks.

What is Portugal FBC or ANPC (Fire Brigade Charge)?

The Portuguese Fire Brigade Charge (FBT), commonly referred to in the insurance market as the ANPC charge, is a parafiscal levy imposed on insurance premiums covering fire risks.

It is administered by the Autoridade Nacional de Emergência e Proteção Civil (ANEPC), formerly known as the Autoridade Nacional de Proteção Civil (ANPC) until that body was restructured and renamed in 2019. The acronym ANPC remains in widespread use as a shorthand for the charge itself. The charge applies to policies falling within insurance classes 3 to 13 where a fire peril element is present.

Some tax specialists and market practitioners still refer to the fire brigade charge informally as the “SNB charge”, reflecting the body that originally administered it. For them and also for those wishing to trace the fuller institutional history of the ANEPC, here is a brief history of the institution behind the charge. ANEPC predecessor bodies date back to the Serviço Nacional de Bombeiros (SNB), established in 1979 to oversee fire brigade services in Portugal.

In 2003, the SNB merged with the Serviço Nacional de Proteção Civil (SNPC) to form the Serviço Nacional de Bombeiros e Proteção Civil (SNBPC). This in turn became the Autoridade Nacional de Proteção Civil (ANPC) in 2007, before being restructured as the ANEPC in 2019. The fire brigade charge and its evolving ANPC or SNB abbreviations reflects this long institutional history.

The standard ANPC rate is 13% of the fire risk portion of the premium. In practice, where a policy covers fire risk alongside other perils, the fire proportion is typically set at 30% of the written premium. Accordingly, the effective ANPC rate in most cases is 3.9% (13% × 30%). Where the fire proportion is not separately identified in the policy documentation, market practice assumes a 30% fire proportion by default.

A reduced ANPC rate of 6% applies specifically to agricultural and livestock insurance premiums. ANPC is not remitted directly to the civil protection authority; instead, it is settled monthly to the ASF (Autoridade de Supervisão de Seguros e Fundos de Pensões), the insurance supervisory authority that administers all parafiscal charges on behalf of the relevant public bodies.

A five-yearly ANPC summary report was historically required by the ASF, however this obligation has since been abolished and is no longer an active requirement.

As in case of Stamp Duty, ANPC obligation should be split by Portuguese region (Mainland, Azores and Madeira) based on the postcodes of the associated risks.

What parafiscal levies exist in Portugal?

Portugal is notable among EU insurance markets for the breadth of its parafiscal surcharges. A parafiscal tax is a levy on a product or service that a government charges for a specific purpose, typically to fund a designated public body or sector. In Portugal, these charges are applied on top of Stamp Duty and must be settled separately, each with its own rate, applicable class of business, and reporting schedule.

The principal parafiscal charges applicable to insurance premiums in Portugal are as follows:

• ANPC (administered by ANEPC), the Fire Brigade Charge, as described above: 13% of the fire premium (typically 3.9% effective rate), applicable to classes 3–13.
• ASF (Autoridade de Supervisão de Seguros e Fundos de Pensões), the supervisory levy: 0.242% of net premium income for non-life insurance, and 0.078% for life insurance (rate applicable from 2026, increased from the previous 0.048%). Reported and paid to the ASF on a half-yearly basis (January and July), with reference to the preceding semester
• INEM (Instituto Nacional de Emergência Médica), the National Medical Emergency Contribution: 2.5% of the taxable premium, applicable to life (death cover and supplementary covers), sickness, accident, motor vehicles, and motor liability insurance (classes 1, 2, 3, 10 and 18). Reported monthly, with an additional annual summary report submitted directly to the INEM.
• FGA (Fundo de Garantia Automóvel), the Motor Guarantee Fund Contribution: 2.5% of the compulsory third-party liability premium, applicable to class 10 (motor liability) only. Reported and paid quarterly.
• PR (Prevenção Rodoviária), the National Road Safety Authority Contribution: 0.21% of the premium for motor-related classes (classes 1, 3 and 10). Reported and paid quarterly.

The ASF acts as the central collection point for parafiscal taxes in Portugal. ANPC and INEM liabilities are remitted monthly; ASF on a half-yearly basis; and FGA and PR on a quarterly basis.

Similarly to Stamp duty, insurers must ensure that their premium data is correctly split by Portuguese region (Mainland, Azores and Madeira) for ANPC and INEM, as declarations must reflect the regional distribution of premiums.

Unlike the significant reporting changes that affected Stamp Duty declarations from 2020 onwards, the parafiscal tax frameworks and their underlying rates have remained broadly stable for many years. The one structural exception is the ASF supervisory levy, whose rate is confirmed annually by ministerial order and is therefore subject to adjustment as demonstrated by the increase in the life insurance rate from 0.048% to 0.078% effective from 2026.

Who is liable, policyholder or insurer?

In Portugal, the insurer is the taxable person legally responsible for calculating, declaring, and remitting Stamp Duty to the Portuguese Tax and Customs Authority (AT). The economic burden of the tax is, however, passed on to the policyholder as part of the total premium charged.

The same principle applies to parafiscal surcharges. The insurance company is legally liable for collecting and remitting ANPC, ASF, INEM, FGA, and PR to the relevant authorities. These charges are generally borne by the policyholder as part of the total cost of cover, with the insurer acting as the collection and reporting agent.

Location of Risk Rules

“Location of risk” is the principle that determines whether Portugal has the right to tax an insurance premium. The Portuguese rules follow the EU Insurance Distribution Directive principles and are consistent with those applied across EU member states. Stamp Duty, ANPC, and all other parafiscal charges apply to premiums where the risk is located in Portugal, regardless of the law applicable to the insurance contract or the country of establishment of the insurer.

The principal location of risk rules under Portuguese law are as follows:

• Immovable property (buildings): The risk is located where the property is situated.
• Vehicles (motor vehicles, ships, yachts and aircraft): The risk is located in the country where the vehicle is registered.
• Travel insurance: For travel risks of a duration of four months or less, the risk is located in the country where the policyholder took out the policy.
• All other risks: The risk is located where the policyholder, if an individual, is habitually resident, or, in the case of a corporate insured, where the establishment to which the policy relates is situated.

A particularly important feature introduced since January 2020 is the requirement to report the precise regional location of risk within Portugal, that is, whether the risk is located in Mainland Portugal (Continente), the Azores, or Madeira. This regional split must be reported at individual policy level in each monthly Stamp Duty declaration, using the relevant postcode where available or add letters such as C, A or M.

Parafiscal charges such as ANPC and INEM are subject to the same regional reporting requirements.

Broker commissions on insurance contracts covering Portuguese risks represent a further dimension of the Portuguese location of risk rules. Whilst a strict reading of the CIS territoriality rules could suggest that commissions paid to brokers based outside Portugal fall outside the scope of Portuguese Stamp Duty, but the Portuguese Tax Office has issued guidance that may be read contrary this view. This may create an unresolved tension between the legislative text and the potential interpretation of the Portuguese Tax Office, leaving open the question of whether Stamp Duty applies to commissions solely by reference to where the underlying risk is located, or by reference where the broker is established or both.

What are the Stamp Duty and parafiscal charges rates and components in Portugal?

The standard Stamp Duty rate on insurance premiums in Portugal is 9%, applying to the majority of non-life insurance classes including general liability, property, motor, fire, and commercial risks.

However, several reduced and special rates apply depending on the class of business:

• 9% standard rate: applies to most general (non-life) insurance classes, including motor liability, fire, general liability, and property insurance.
• 5% reduced rate: applies to marine and aviation insurance, goods in international transit, agricultural insurance, and personal accident insurance.
• 3% further reduced rate: applies to suretyship.
• On suretyship policies a further SD applied on the amount of the guarantee. The rate is either 0.4% per month, 0.5% or 0.6% per year depending on the length of the guarantee.
• 2% broker commissions: applies to broker commissions on insurance contracts.
• Exempt: Life insurance premiums: exempt from Stamp Duty (though life risk elements may be subject to INEM at 2.5%).

In addition to Stamp Duty, the following parafiscal rates apply:

• ANPC: 13% on the fire proportion of the premium (typically 3.9% effective rate, assuming a 30% fire proportion; or 6% for agricultural insurance).
• INEM: 2.5% of gross premium for applicable classes (life/death, sickness, accident, motor vehicles, motor liability).
• ASF: 0.242% of net premium income for non-life classes; 0.078% for life insurance (from 2026, previously it was 0.048%).
• FGA: 2.5% of the compulsory motor liability premium (class 10 only).
• PR: 0.21% of premium for motor-related classes (classes 1, 3 and 10).

The cumulative effect of Stamp Duty and parafiscal charges means that the total tax burden on certain classes of Portuguese insurance can be materially higher than the headline 9% Stamp Duty rate alone might suggest. For a standard property insurance policy with fire cover at 30%, the combined charges include 9% Stamp Duty, 3.9% ANPC, and 0.242% ASF producing a total effective levy above 13%.

Portugal Stamp Duty exemptions

Portugal Stamp Duty on insurance premiums includes a number of important exemptions. Understanding when these exemptions apply is essential for accurate Portuguese insurance tax compliance.

The key exemptions from Stamp Duty are:

• Life insurance: Premiums under life insurance contracts (including unit-linked and savings products) are exempt from Stamp Duty.
• Reinsurance: Premiums ceded under reinsurance contracts are exempt from Stamp Duty, as the tax is levied at the direct insurance level.
• Export credit insurance: premiums under export credit insurance, surety insurance, and bank guarantees in external trade were granted a Stamp Duty exemption.

A further exemption applies to entities licensed in the Madeira and Santa Maria free trade zones (the International Business Centre of Madeira, or CINM), as well as to the companies to which the concession of those zones has been granted. Such entities benefit from an 80% reduction in Stamp Duty on documents, contracts, and other operations, including insurance premiums, provided that the counterparties to the transaction are either non-residents of Portuguese territory or are themselves licensed within the CINM framework. This produces an effective Stamp Duty rate of approximately 1% on standard insurance premiums for qualifying entities under the current regime (Regime IV).

It is important to note that while life insurance premiums are exempt from Stamp Duty, they are not entirely free of fiscal obligations. Life risk (death) premiums and supplementary covers remain subject to the INEM parafiscal contribution at a rate of 2.5%. Similarly, ASF supervisory levies apply to life insurance at 0.078% (from 2026, previous rate was 0.048%) of net premium income, reported on a half-yearly basis. Insurers must therefore distinguish carefully between the Stamp Duty exemption and the continued parafiscal obligations that apply to exempt classes.

Legal basis

The legal basis for Portuguese Insurance Premium Tax is the Stamp Duty Code (Código do Imposto do Selo, or CIS), approved by Law 150/99 of 11 September 1999. The CIS, together with the General Table (Tabela Geral do Imposto do Selo), sets out the transactions and instruments subject to Stamp Duty, the applicable rates, and the exemptions available. Insurance contracts and premiums are governed by specific provisions within the General Table, which prescribe the rates applicable to each class of business.

The CIS has been amended on multiple occasions since its enactment, with significant reforms introduced in 2019 (Law Decree 119/2019 and Law Decree 339/2019) to modernise the reporting framework and introduce the monthly electronic declaration requirement at policy level.

The ANPC fire brigade charge is governed by specific civil protection legislation, with collection and administration delegated to the ASF.

The ASF supervisory levy is established annually by ministerial order under the Insurance and Pension Funds framework (Lei de Bases dos Seguros).

The INEM contribution is set under the legislative framework governing the National Medical Emergency Institute.

The FGA and PR contributions are governed by motor insurance legislation, including the relevant decree-laws implementing EU motor insurance directives into Portuguese law.

The administering authority for Stamp Duty is the Autoridade Tributária e Aduaneira (AT), the Portuguese Tax and Customs Authority. All parafiscal charges are collected and administered by the ASF, which acts as the central intermediary between insurers and the various public bodies that benefit from these levies.

What is the filing frequency and reporting requirements for Stamp Duty and parafiscal charge declarations in Portugal?

Portugal operates a mandatory monthly reporting regime for Stamp Duty. All insurers covering Portuguese risks must submit a Monthly Stamp Duty Declaration electronically to the AT by the 20th day of the month following the reporting period. This obligation was formalised by Law Decree 339/2019 of 1 October 2019 and applies to all transactions, including those that are exempt from Stamp Duty.

The declaration must be submitted electronically and must include, at individual policy level, the following data:

• The policyholder’s Tax Identification Number (NIF in Portugal, or the equivalent foreign TIN preceded by the relevant ISO country code for non-Portuguese policyholders).
• The territoriality of the risk that is, whether it was issued within or outside Portuguese territory.
• The precise regional location of the risk within Portugal: Mainland (Continente), the Azores, or Madeira, identified by postcode where available.
• The class of business and the premium amount subject to Stamp Duty or claimed as exempt.

For parafiscal charges, the reporting and payment schedules differ by charge type:

• ANPC and INEM: monthly reporting and payment to the ASF, with premiums split by Portuguese region (Mainland, Azores, Madeira). INEM also requires an annual summary report submitted directly to the INEM.
• FGA and PR: quarterly reporting and payment to the ASF on two separate returns.
• ASF supervisory levy: half-yearly reporting and payment to the ASF (January and July, with reference to the preceding semester).

An important and often overlooked requirement is that each EU/EEA branch of an insurer must register separately for parafiscal charges although stamp duty obligations are reported under the Head Office. This requirement adds a significant administrative overhead for EU/EEA insurers operating cross-border into Portugal via several branches across Europe.

Updates on Portugal Stamp Duty and Parafiscal Charges

The Stamp Duty framework for insurance has a long legislative history in Portugal, with roots tracing back to the Royal Decree of 1660. The modern CIS was introduced in 1999 and has been subject to periodic reform, with the most significant recent changes affecting the reporting regime and data requirements rather than the underlying tax rates.

Key milestones in the recent legislative development of Portugal Stamp Duty and parafiscal charges include:

• 1999: Introduction of the modern Stamp Duty Code: Law 150/99 of 11 September approved the Código do Imposto do Selo (CIS), consolidating and modernising the legal framework for Stamp Duty.
• 2019: Reporting modernisation: Introduction of the obligation for monthly electronic Stamp Duty declarations at individual policy level, requiring insurers to report policyholder TINs, regional location of risk, and territoriality data. The offsetting mechanism for prior-period adjustments was abolished, replaced by the Replacement Declaration procedure. The ANEPC was simultaneously established (replacing ANPC)
• 2020: Effective implementation of enhanced reporting: From January 2020, all insurers covering Portuguese risks became subject to the new policy-level reporting requirements, with a transition window to April 2020.
• 2024: Updated Monthly Stamp Duty Declaration model for the Monthly Stamp Duty Declaration (DMIS) and its completion instructions, taking effect from 1 October 2024. This updated the earlier model including updates for exemption codes.
• 2026: ASF life insurance levy rate increase: The ASF supervisory levy applicable to life insurance premiums was increased from 0.048% to 0.078% of net premium income, effective from 2026.

A notable proposed update during 2026 was the legislative proposal to increase the INEM medical emergency contribution from its current rate of 2.5% to 3.5%. However, the proposal did not progress through the legislative process and was not enacted into law, meaning the INEM levy remains at 2.5% for the time being. Insurers and compliance managers should nonetheless continue to monitor developments in this area, as the proposal signals a potential appetite for upward revision of parafiscal charges in Portugal.

What are the Stamp Duty challenges in Portugal?

The main compliance challenges in Portugal relate to the breadth and complexity of the reporting obligations, the multiple parafiscal charges with differing rates and schedules, and the granular data requirements introduced since 2020.

The policy-level reporting obligation is particularly demanding. Insurers must collect and validate each policyholder’s TIN (or foreign equivalent with the correct ISO country code), correctly identify the regional location of risk within Portugal for every individual policy, and split premiums accordingly.

A related challenge concerns the requirement for separate registration and reporting for each EU/EEA branch for parafiscal charges.

Beyond the above, insurers must also split premium data by region, which are Mainland (Continente), the Azores, and Madeira, across both the monthly Stamp Duty declaration and the parafiscal returns for ANPC and INEM. Each autonomous region operates its own fiscal jurisdiction, meaning that incorrectly allocating a risk to the wrong region can result in underpayment in one territory and overpayment in another, both of which carry compliance consequences.

The broker commission Stamp Duty ambiguity is a further area of practical difficulty. Whilst the CIS territoriality rules could be read to suggest that commissions paid to non-resident brokers fall outside the scope of Portuguese Stamp Duty, the Tax Office has issued guidance which might be read that stamp duty still applies in these cases as well.

The abolition of the prior-period offsetting mechanism since 2019 also increases the cost of error correction. There is a complex methodology of the negative offsets. Overpayments must now be reclaimed through a formal Replacement Declaration process, adding administrative burden and cash-flow implications for insurers who discover prior-period discrepancies.

And not to be overlooked is the requirement to keep pace with updates to the official Monthly Stamp Duty Declaration (DMIS) model. It was last updated in 2024 following earlier updates in 2019 and 2021. Failing to use the current model or apply the correct exemption codes can result in rejected submissions and compliance exposure.

How Sovos helps with Portugal Stamp Duty and parafiscal compliance

Sovos’ IPT Managed Services ensures your business complies with the latest Insurance Premium Tax and parafiscal charge requirements in Portugal, including the monthly Stamp Duty declaration, ANPC, INEM, ASF, FGA, and PR obligations.

Sovos has developed a unique working relationship with the Portuguese tax authority, enabling comprehensive and validated reporting between Sovos systems and the AT’s API, facilitating efficient policyholder TIN validation and policy-level data submission.

Need to ensure compliance with the latest Portuguese Stamp Duty and parafiscal regulations? Get in touch with our tax experts today.

FAQ