Portugal’s state budget entered into force on 27 June 2022 after protracted negotiations. The budget contained an interesting provision: the obligation to present invoice details to the tax authorities was extended to all VAT-registered taxpayers including non-resident taxpayers, who had long been exempt from this obligation.
VAT-registered non-residents now have three options for communicating invoice details:
In practice, the Billing SAF-T file is the least onerous option for taxpayers. It is worth discussing the contents of this file, which is submitted separately from Portugal’s Accounting SAF-T file.
Portugal was the first country in the world to adopt SAF-T, and its requirements are based on the original OECD 1.0 schema. The current schema for the Billing SAF-T is set out in Portaria no. 302/2016 consisting of a specified header, master files, and source documents.
Master files can include customer and/or supplier tables, product tables, and tax tables. Source documents can include sales and purchase invoices, documentation on movements of goods, and payment information, as applicable. For the most part, information in the schema is conditionally required, meaning most fields only need to be submitted if the relevant data exists in a taxpayer’s source system.
Importantly, the Billing SAF-T file must be generated by “certified billing systems,” as designated by the tax authorities, a requirement unique to Portugal. As of 2021 this requirement extends to non-resident taxpayers as well, a strong indicator that they would eventually be required to submit Billing SAF-T.
Although the Billing SAF-T only has four sections, it is nevertheless a complex file to generate. Portaria no. 302/2016 containing guidance on fields and definitions is over 100 pages long in the official gazette. Taxpayers must be able to generate required fields within their source systems and must know what conditionally required data they are able to provide.
The latest state budget has adjusted the monthly deadline for submitting Billing SAF-T. The deadline is now the fifth day of the month following the reporting period, previously taxpayers could submit by the twelfth day of the month following the reporting period.
For these reasons, the introduction of this obligation to non-resident taxpayers represents a significant burden. Existing and potential non-resident taxpayers in Portugal should immediately familiarise themselves with the Billing SAF-T requirement and ensure they are using certified billing software to remain compliant.
Need to ensure compliance with Portugal’s Billing SAF-T requirements? Get in touch with our tax experts.
Electronic invoicing is rapidly becoming a standard business process. Governments are pushing for the adoption of B2G invoicing to optimize the public procurement process and also to provide a boost to the adoption of e-invoicing between businesses.
Apart from countries that have introduced general e-invoicing mandates to improve fiscal controls – most of which have so far been in Latin America – countries in Europe and some in Asia are looking towards the PEPPOL framework to generate both business process and fiscal benefits through standardization.
PEPPOL was established to simplify interoperability, initially for public procurement transactions, but it is being built upon to encompass fiscal reporting or invoicing ‘clearance’ concepts as well.
As part of harmonizing and digitizing public procurement processes within the EU, governments and other public bodies under Directive 2014/55/EU are required to be able to send and receive electronic invoices in accordance with the European Standard EN-16931.
All EU Member States’ public administrations had to be able to receive e-invoices at least for public procurement transactions either by November 2018 or by April 2019, with the possibility for Member States to extend the deadline by one extra year for sub-central authorities.
Several countries have taken the opportunity to generally mandate B2G electronic invoicing when implementing the Directive 2014/55/EU, so that both the public sector and private sector supplier will be obliged to send invoices electronically in B2G transactions.
Examples of countries that have introduced B2G mandatory e-invoicing are Sweden, Croatia, Estonia, Lithuania and Slovenia, and there is an upcoming mandate in Portugal that will come into force for all companies by January 2022. Finland is aiming for the same effect through a buyer-initiated mandate for the supplier to send e-invoices.
The PEPPOL project was initiated in 2008. One of its main objectives was standardization of the public procurement process in European governments. PEPPOL is a set of artifacts and specifications created to enable cross-border e-procurement, supported by a multi-lateral agreement structure which is owned and maintained by the OpenPEPPOL association.
PEPPOL aims to remove complexity around interoperability, as all parties that use PEPPOL will adhere to the same regulations and technical standards to exchange e-documents. Through the PEPPOL network, companies can exchange electronic procurement documents including e-Orders, e-Advance Shipping Notes, e-Invoices and e-Catalogues via access points based on what is known as a four-corner model – meaning that suppliers and buyers are represented by service providers that process data on their behalf.
While PEPPOL is known to have its initial focus in Europe, it is expanding beyond the EU to Asia and recently has also received more attention in the Americas. Singapore was the first country in Asia and the first outside Europe to establish a PEPPOL Authority, facilitating the framework on a national level, but was soon followed by other countries.
Currently, there are OpenPeppol members in 31 countries. In addition to countries in Europe, these include Australia, Canada, China, Japan, Mexico, New Zealand, Singapore and USA, with Japan being the newest addition.
As explained above, several EU Member States took the opportunity when transposing the Directive 2014/55/EU to make B2G e-invoicing mandatory.
More countries are now following that path:
Developments in B2G e-invoicing can no longer be considered separate from B2B e-invoicing. After all, many companies supply goods or services to public authorities, and investments in complying with government customer requirements under schemes like PEPPOL will drive the use of these same standards and rules in the business-to-business sector.
This also means that initiatives towards business-to-business electronic invoicing as a way for tax administrations to receive VAT-relevant data in real-time or near-real-time are increasingly influenced by concepts from the public procurement world.
This spillover goes well beyond conceptual inspiration. In Italy, for example, support for mandatory e-invoicing for VAT control purposes in 2019 was built on a massive data processing platform that was initially designed to facilitate public procurement. France and Poland are far down the path of similar architectures for their continuous transaction controls plans.
As PEPPOL becomes more popular as a standard to make country-specific public procurement methodologies more easily accessible for suppliers abroad, its concepts will increasingly penetrate the broader worlds of electronic invoicing, electronic trade and fiscal compliance.
Need to ensure compliance with the latest e-invoicing regulations? Get in touch with our tax experts.
Update: 24 September 2025
Insurance Premium Tax (IPT) regulations in Spain are among the most intricate within the European Union.
Compliance is particularly challenging due to the involvement of multiple tax authorities. These include the central tax administration – commonly referred to as “HACIENDA/AEAT” (Agencia Estatal de Administración Tributaria) – as well as four provincial tax offices in the Basque Country: Álava, Guipúzkoa, Navarra, and Bizkaia.
In addition to IPT, insurers are also subject to extraordinary surcharges on some of the risks. These surcharges must be paid to the Consorcio de Compensación de Seguros (Consorcio). Furthermore, fire brigade contributions are due either to GESTORA (Gestora de Conciertos para la Contribución a los Servicios de Extinción de Incendios) if the insurance company is a member of GESTORA, or to over 300 municipalities without membership. Municipal FBC (MFBC) may also be payable to certain municipalities within the Madrid region.
Given this complex landscape, navigating Spain’s IPT framework and maintaining compliance can be particularly demanding. To support insurers in this effort, SOVOS has developed this guide to address key questions and provide clarity on the nuances of Insurance Premium Taxation in Spain.
While not all taxes apply to every insurance risk, the applicable obligations vary based on the nature of the coverage. Navigating Spain’s Insurance Premium Tax (IPT) framework requires a solid understanding of more than five distinct taxes and contributions.
Below are the most encountered taxes and surcharges in Spain:
Insurance Premium Tax (IPT) in Spain must be paid to one of five different tax authorities, depending on the postcode of the insured risk location. While most liabilities are reported to the central tax administration, known as “Hacienda” (Agencia Estatal de Administración Tributaria), some Basque regions have their own tax offices.
The first two digits of the five-digit Spanish postcode determine the appropriate tax authority for IPT reporting. If the postcode begins with one of the designated codes for the Basque provinces, as listed below, IPT must be paid to the corresponding regional tax office. For all other postcodes, IPT is payable to the central tax administration.
In addition to registering with the central tax administration (Hacienda), insurers must register with the relevant provincial tax office corresponding to the location of the insured risk, where applicable.
The current IPT rate in Spain is 8% as of 2021, and it is applied to all classes of insurance, with some exemptions.
Certain classes of insurance businesses are exempt from Insurance Premium Tax (IPT) in Spain. These exemptions typically include life, health, reinsurance, export credit, suretyship, and international coverage across various sectors such as marine and aviation. Agricultural risks may also qualify for exemption, depending on the specific circumstances.
The basis for calculating Insurance Premium Tax (IPT) in Spain is the total premium amount payable by the insured. Depending on how the Fire Brigade Charge (FBC /MFBC) is levied, it may also be included in the taxable base for IPT purposes.
The insurer is responsible for calculating, collecting and remitting the Insurance Premium Tax (IPT) to the appropriate tax authority, in accordance with the filing and submission requirements established by each respective office.
Although Insurance Premium Tax (IPT) is classified as an indirect tax, insurance companies are not currently required to submit real-time transactional data through Spain’s Immediate Supply of Information (SSI) system, which is already in use for VAT reporting. However, future developments are expected to move IPT submissions toward greater automation, aligning more closely with VAT processes. At present, IPT reporting involves both monthly and annual declarations:
IPT filings in Spain are submitted online and may require varying levels of detail, such as a breakdown by covered risks.
CCS or Modelos are administered by Consorcio de Compensación de Seguros (Consorcio). One of the Consorcio’s primary responsibilities is to compensate policyholders when the Spanish government officially declares an extraordinary risk event.
Extraordinary risks generally fall into the following categories:
Each Modelo is subject to its own tax rate and calculation methodology. Below is a high-level summary:
Returns must be submitted on a monthly basis via a dedicated online portal that requires detailed policy-level information. Payment is made through direct debit, which is automatically triggered upon submission of the return.
The Fire Brigade Charge (FBC) is a surcharge applied to insurance premiums that include fire coverage. Depending on the nature of the policy, the tax may be levied on the full premium or only on the portion attributable to fire risk.
Provided that the insurance company is a member of Gestora de Conciertos para la Contribución a los Servicios de Extinción de Incendios (GESTORA), the collection of FBC is centralized by this body. This body operates under the umbrella of UNESPA—the Spanish Association of Insurers and Reinsurers—and represents over 96% of insurance companies in Spain.
However, in the absence of membership, the insurance company should deal with 300+ municipalities in Spain because FBC amounts must be paid individually to the respective municipalities based on the postcode of the insured risks. Therefore, it is strongly recommended to become a member of GESTORA, as this significantly reduces the administrative burden associated with FBC payments.
Two standard rates apply:
Joining GESTORA is administratively challenging, as new members are accepted only once per year. Insurers must submit a formal application during a limited registration window – typically one month in the spring.
FBC settlement spans five years and consists of four phases:
In addition to the National FBC, insurance companies may be subject to a Municipal Fire Brigade Charge (MFBC) if the insured risks are located in the Region of Madrid, because some Madrid Councils have implemented a municipal levy (MFBC). MFBC rates vary by municipality and coverage type, ranging from 5% to 30%, and may be structured as either fixed or variable. The declaration period is typically annual.
Need more information? Our team of tax experts are ready to help. Get in touch today.
Update: 25 August 2023 by Carolina Silva
According to official sources from the Ministry of Finance, the Croatian tax authority will introduce a decentralised e-invoicing model alongside a continuous transaction control (CTC) real-time reporting system of invoice data to the tax authority. This move is part of the Fiscalization 2.0 project the authority announced earlier this year.
This is the outcome of a recent project where the tax authority analysed CTC clearance and reporting systems from multiple jurisdictions within the EU – i.e. Spain, France, Italy and Hungary – which all have the common purpose of combating VAT fraud. Further examination of the efficacy of such systems revealed that these procedures are successful in this fight and increase VAT revenue.
According to recent news, there will be a phased implementation of two obligations:
These are two independent obligations for taxpayers and take place separately.
Trading parties will issue and exchange e-invoices and, in parallel, each party will deliver certain invoice data to the fiscalization system within a two-day deadline. The e-invoicing process and data reporting to the fiscalization system can both be performed through service provider access points.
Companies will not perform the e-invoice exchange through a centralised platform but through access points; they can outsource their e-invoicing and real-time reporting processes to service provider access points. To this end, the tax authority will make a directory of access points available.
The Croatian tax authority will use data obtained from the fiscalization of invoices to simplify and facilitate the existing VAT reporting obligations (i.e. forms, records and tax returns), ultimately replacing some of the current returns. Measures proposed are:
The proposed system should be implemented by the end of 2024, giving time for the necessary adjustments of the current legal framework to be made and for publishing further CTC documentation and specifications before the implementation begins.
Need help preparing for these upcoming changes in Croatia? Sovos can help.
Update: 13 February 2023 by Carolina Silva
The Croatian Tax Administration has announced a new project called “Fiscalization 2.0”, which would implement a broad CTC system that combines e-reporting, mandatory e-invoicing, e-archiving and e-bookkeeping obligations.
Fiscalization 2.0 seems to be an extension of Croatia’s current fiscalization system for cash transactions, called online fiscalization. The government is looking at other CTC systems in Europe, and specifically mandatory B2B e-invoicing, as the vehicle to achieve business automation and tax autonomation in the Croatian economy.
Based on the announcement, it is not clear yet what form of CTC system may be implemented and what the requirements will be.
Croatia’s proposed measures are:
The project should be implemented by the end of 2024, giving the authorities enough time to produce necessary CTC legislation and documentation and prepare businesses to comply with the new requirements.
Expect the Croatian Tax Administration to publish further documentation and specifications before implementation.
Currently, the tax administration is forming working groups to jointly study the best practices and find the right solutions for the new CTC system. Additionally, the tax authority is conducting a survey on the current state of e-invoicing in the country and expectations for the future.
For more information on Croatia’s evolving fiscalization system, speak to our expert team.
Update: 8 April 2021 by Joanna Hysi
Croatia was one of the first countries in the world to introduce a real-time reporting system for cash transactions to the tax authority. Known as the online fiscalization system, new requirements have been introduced to improve tax controls for cash transactions.
The system aims to combat retailer fraud by providing the tax authority with visibility of cash transactions in real-time and encouraging citizens to play a part in tax controls by validating the fiscal receipt through the tax authority’s web application.
Previously, the online fiscalization system required issuers to send invoice data to the tax authority for approval and include a unique invoice identifier code (JIR) provided by the tax authority in the final receipt issued to the customer. Registration of the sale could be verified by entering the JIR code through the tax authority’s web application.
The government has introduced a new requirement for fiscal receipts to make citizen participation easier and increase the level of control of tax records and evidence.
As of 1 January 2021 a QR code must be included in fiscalized receipts for cash transactions. Consumers can now validate their receipts by entering the JIR via the web application or by scanning the QR code.
As part of the tax reform, a new procedure for fiscalization of sales via self-service devices came into force on 1 January 2021.
To implement the fiscalization procedure via self-service devices, the taxpayer must enable the use of software for electronic signing of sales messages and provide internet connection for electronic data exchange with the tax administration.
When implementing the fiscalization of self-service devices only the sale is fiscalized and sent to the tax administration, no invoice is issued to the customer.
Secondary legislation specifying the process and measures for data security and exchange has still not been published despite the requirement having gone live, but is expected in the near term.
To learn more about European VAT compliance download our eBook. Follow us on LinkedIn and Twitter to keep up-to-date with regulatory news and updates.
By Andy Hovancik – President & CEO
Today, we announced the acquisition of Stockholm-based TrustWeaver to create a clear leader in modern tax software.
TrustWeaver has become a seal of approval for the world’s largest procure-to-pay and AP systems. This is a testament not only to the effectiveness of its e-invoicing software and integrations, but also to its ability to monitor and interpret regulatory change around the world.
With the acquisition, we are poised to do three big things together:
Governments are quickly adopting digital models to better collect every type of transactional tax, including VAT, GST and sales & use tax. As a result, businesses are faced with mounting complexity, rising costs and unparalleled risks.
Last month, the European Commission granted Italy permission to mandate e-invoicing, making it the first country in the European Union to do so. Italy’s move paves the way for rapid expansion of real-time, transaction-level reporting in Europe.
Here at Sovos, we’ve assembled the only solution capable of dealing with the complexities of modern tax, a complete software platform with global tax determination, complete e-invoicing compliance and a full range of tax reporting solutions including e-accounting and e-ledger.
TrustWeaver is our third e-invoicing acquisition in two years, and it’s one of the most important acquisitions in our history.
TrustWeaver has built up coverage across Europe, the Middle East, Africa and Asia Pacific regions, complementing our strength in Latin America. And, it adds support for “post-audit” compliance, including e-signatures in compliance with the eIDAS Regulation, which is an onerous set of standards for electronic trust and identification in Europe.
With the addition of TrustWeaver, we’re one step closer to our mission, which is to reduce the friction between businesses and governments so commerce can grow faster and communities can thrive by simply collecting the tax they’re already owed.
Read the IDC Link: Sovos Acquires TrustWeaver, Strengthening its Market Position, May 17, 2018 by Kevin Permenter.
Find the Sovos E-Invoicing solutions here.
Earlier today, we announced that Sovos has acquired U.K.-based FiscalReps, Europe’s leading solution for Insurance Premium Tax (IPT) compliance. The acquisition does a few important things for our clients and the market as a whole:
Here’s what Sovos CEO Andy Hovancik had to say about the news:
“Insurers across Europe trust FiscalReps because the solution safeguards their businesses from mounting risks from governments looking to close longstanding gaps in IPT compliance. The addition of FiscalReps presents an opportunity to better prepare insurers for the digital future of tax compliance and reporting, while at the same time adding a talented team to support our clients in the region.”
Similar to other indirect tax regulations, IPT compliance has become increasingly burdensome in recent years, requiring insurers to comply with 90 unique taxes and more than 500 complex forms in the European region alone. As governments turn to technology to clamp down on non-compliance, businesses have quickly turned to automation.
Through a combination of managed services and software, FiscalReps helps more than 400 businesses — including 20 of the top 50 insurance companies in Europe — calculate and file IPT in 27 European countries. FiscalReps gives those businesses a more automated and more accurate solution for filing thousands of IPT reports each year.
The addition of FiscalReps to Sovos’ cloud software platform takes the solution one step further, according to FiscalReps CEO Mike Stalley, setting the stage for a unique global solution for the insurance market and accelerating software innovation in IPT compliance.
“The acquisition by Sovos is a great opportunity for our insurance clients, who will now have a truly global solution for all of their premium tax and regulatory reporting needs,” Stalley said. “With a proven track record in delivering tax technology solutions globally, the Sovos strategy aligns perfectly with FiscalReps’ ambitions to remain the market leader in this increasingly complex and challenging environment. We look forward to being part of the Sovos team and contributing to the success story.”
The FiscalReps acquisition is the second major deal in three months for Sovos, following the acquisition of Paperless, a leading software solution for a similar compliance challenge, real-time VAT reporting. For the past few years, we have been actively acquiring leading software businesses around the globe and integrating them into our Intelligent Compliance Cloud, an approach that is critical to keeping businesses ahead of disruptive tax and regulatory reporting requirements.
“The IPT market is another great example of governments pushing businesses toward global software automation by getting aggressive on enforcement of regulations to collect tax revenue,” Gledhill said. “As that trend continues to accelerate, Sovos is committed to adding market-leading solutions, like FiscalReps, to solve our clients’ biggest compliance challenges on a single platform and from a single source of data.”
Learn more about Sovos IPT Determination and Sovos IPT Managed Services here. You want to learn more about IPT? Read this guide about Insurance Premium Tax.