Portugal’s VAT Regime

Portugal pushes further ahead with VAT digitization

Back in 2019, Portugal passed a mini e-invoicing reform consolidating the country’s framework around SAF-T reporting and certified billing software.

Since then, a lot has happened: non-resident companies were brought into the scope of e-invoicing requirements, deadlines were postponed due to Covid, and new regulations have been published.

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Quick facts

Use of certified billing software is mandatory for the creation of all types of invoices (paper or electronic); this is understood to be the taxpayer’s ERP system. Non-resident companies with a Portuguese VAT registration have also become obligated to issue invoices and other fiscally relevant documents via a certified billing software, since 2021.
A QR code should be included in all invoices issued through a certified billing software. Technical specifications about the content and placement of the code in the invoice are available on the tax authority’s website.
A unique ID number (ATCUD) must be included in all invoices and fiscally relevant documents. The ATCUD is a number with the following format ‘ATCUD:Validation Code-Sequential number’.
Public entities must receive e-invoices whilst companies must send e-invoices since 1 July 2021. E-invoices must be issued electronically in the CIUS-PT format and transmitted to the public administration through one of the available web services.
A qualified electronic signature or seal, or the use of EDI with contracted security measures is mandatory for all electronic invoices from 1 January 2024.
Billing SAF-T has monthly submission requirements and must be completed with the normal VAT return by the 5^th (until the 8th during the year of 2023 due to a grace period) day of the month following the reporting period. The Billing SAF-T may be submitted via the e-fatura portal or through web services.
Accounting SAF-T: annual submission is mandatory from 2026 via the tax authority´s portal which will enable automatic pre-filling of the VAT IES´ Annexes.

Important dates

1 July 2021: Non-resident taxpayers required to use a certified billing software to issue invoices and other fiscally relevant documents.
Issuance of B2G e-invoices:
1 January 2021: Phased rollout of mandatory issuance of e-invoices in the CIUS-PT format for large suppliers of the public administration.
1 January 2022: QR code requirement implemented for invoices and other fiscally relevant documents issued through a certified billing software.
1 January 2023: Unique ID number (ATCUD) is mandatory on all paper and electronic invoices.
1 January 2023: Non-resident taxpayers required to submit Billing SAF-T monthly.
2025 fiscal year: Mandatory annual submission of accounting SAF-T for residents and non-residents (first submission occurs in 2026 regarding the fiscal year of 2025)
1 January 2025: Mandatory B2G E-invoicing extended to include small and medium-sized businesses.
1 January 2025: Qualified electronic signature/seal or EDI mandatory for electronic invoices.

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