Portugal: Changes concerning self-billed invoices

Gabriel Pezzato
December 27, 2022

The Portuguese government published Decree-law no. 85/2022 amending Decree-law no. 198/2012 to change provisions concerning the communication of self-billed invoice elements to the tax authority (TA) via the E-Fatura Portal.

The amendments were made to article 3 of the above-mentioned decree-law to clarify and include reporting obligations in case of self-billing. The following measures were enacted and come into force starting 1 January 2023:

  • Self-billing without prior agreement: It will be mandatory for the buyer to communicate invoice data. This applies, more specifically, to the recyclable scrap regime, forest goods regime and micro-production of electricity regime, according to article 29 (15) of the Portuguese VAT Code. Additionally, the supplier of the goods or services will have the possibility to indicate in the TA´s Portal the existence of invoices that do not comprise transfer of goods or services rendered by them, until the 25th of February of the year following the issuance of the invoice.
  • Self-billing with prior agreement: The communication of invoice data to the TA´s Portal may be performed by the buyer.

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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).
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