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.

Author

Gabriel Pezzato

Gabriel Pezzato is a Senior 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
Share on facebook
Share on twitter
Share on linkedin
Share on email

North America ShipCompliant
August 9, 2022
2022 Direct-to-Consumer Wine Shipping Mid-Year Report

A lot has changed in the direct-to-consumer (DtC) wine shipping channel since the January release of our Direct-to-Consumer Wine Shipping Report—changes in volume and value that have the market resembling pre-pandemic patterns. Note: The proprietary data featured in this mid-year report is compiled from an algorithm measuring total DtC shipments based on millions of anonymous […]

E-Invoicing Compliance EMEA Italy
August 9, 2022
Italian Import Documents Become Electronic

The Italian Customs Authorities recently updated their national import system by applying the new European Union Customs Data Model (EUCDM). These new changes came into effect on 9 June 2022. According to the new procedure, the old model of paper import declarations has been abolished. The import declarations are now transmitted to the Italian Customs […]

E-Invoicing Compliance EMEA India
August 4, 2022
India: B2C Invoicing QR Code Requirement

In India, the e-invoicing system has been live since 2020. Taxpayers in the scope of e-invoicing mandate must issue their invoices relating to B2B and B2G transactions through the e-invoicing system, which is a form of continuous transaction controls (CTC). However, B2C invoices are not issued through the CTC system, which means that B2C invoices […]

E-Invoicing Compliance EMEA India
August 2, 2022
India: New Taxpayers to Comply with E-invoicing Rules

As previously predicted by Sovos, the threshold for implementing mandatory e-invoicing has been lowered by the Indian authorities. According to the Central Board of Indirect Taxes and Customs Notification No. 17/2022 – Central Tax, from 1 October 2022 compliance with the e-invoicing rules will be mandatory for taxpayers with an annual threshold of 10 Cr. […]

Asia Pacific E-Invoicing Compliance EMEA
August 1, 2022
eGUI: Taiwan’s Approach to Electronic Invoicing

Since 1 January 2020 foreign electronic service providers must issue cloud invoices, a type of e-invoice, for sales of electronic services to individual buyers in Taiwan. Alongside this, Taiwan’s local tax authorities have been introducing incentives for domestic taxpayers to implement e-invoicing despite this not being a mandatory requirement. Before diving into the details of the […]