Brief summary of three new deadlines regarding to invoicing rules in Portugal, published by Decree-Law no. 123/2018, of December 28th and Decree-Law no.28/2019, of February 15th, that apply and should be taken into consideration from January 2020 onwards:

Invoicing communication

From 1 January 2020 onwards, the deadline to communicate the invoices elements through the presentation of the Standard Audit File for Tax purposes (SAFT-PT) to the Portuguese Tax Authorities will be anticipated to the 12th of the following month to which the invoice was issued. Currently, this communication must be done until the 15th of the following month to which the invoice was issued.

Invoicing software certified by the Portuguese Tax Authority

From 1 January 2020, resident entities and non-resident entities with permanent establishment in Portugal are obliged to issue their invoices through a software duly certified by the Portuguese Tax Authorities provided that:

  • As long as they use invoicing software;
  • They are obliged to have organized accounting prepared by a certified accountant (or have opted for it);
  • They have had a turnover higher than €50.000 in the exercise (n-1) or in the first year of activity.

From 1 January 2021, non-resident entities without permanent establishment but with a VAT registration in Portugal are also obliged to the use of invoicing software duly certified by the Portuguese Tax Authorities for the issuance of invoices related to operations that are considered as located in Portugal.

Electronic invoices (e-invoicing)

Electronic invoices for public contracts will be mandatory on:

  • 18 April 2020, for companies which do not qualify as micro, small and medium-sized businesses, as defined in Recommendation no. 2003/361/CE, of 6 May;
  • 1 January 2021, for companies that qualify as micro, small and medium-sized businesses, as defined in Recommendation no. 2003/361/CE, of 6 May.

Notwithstanding, Public Entities as acquirers of goods and services under public contracts will be obliged to receive and process electronic invoices as from:

  • 18 April 2019, for the Portuguese State and for Public Institutes;
  • 18 April 2020, for other public entities.

From 1 January 2021, is mandatory that e-invoices include a bidimensional bar code (QR code). In order to assure the origin authenticity and invoice integrity, it is necessary to have an electronic signature, a qualified electronic seal or the use of an electronic data exchange system (by the European EDI type agreement).

It is recommended that all entities (residents and non-residents) that operates in Portugal should analyze timely their concrete cases in order to be able to comply with Portuguese invoicing rules.

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Sandra Cristina Valente

Sandra Cristina Valente
Tax Compliance Manager Portugal

All information contained in this publication is up to date on 2020. This content has been prepared for general guidance on matters of interest only, and does not constitute professional advice. You should not act upon the information contained in this chart without obtaining specific professional advice. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this content, and, to the extent permitted by law, AUXADI does not accept or assume any liability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this chart or for any decision based on it.