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April 27, 2021

Portugal: Nonresidents must use authorized software to issue VAT invoices from 1 July 2021

The Portuguese Tax Administration (PTA) has clarified that taxable persons who are not resident in the national territory but who are registered for value added tax (VAT), are required to exclusively use software programs previously certified by the PTA for issuing invoices and other relevant tax documents.

This measure applies to taxable persons whose turnover exceeded €50,000 in calendar year 2020 (or if they have been trading for less than a calendar year, if their annualized turnover for that period exceeds €50,000).

The effective date of this requirement is 1 July 2021. The measure was originally due to come into force from 1 January 2021, but it was postponed under Ordinance number 404/2020.XXII.

The updated list of PTA-approved invoicing programs and certified versions, as well as the identification of their producers, has been published on the PTA’s website.


In Portugal, the standard audit file for tax (SAF-T) files are mandatory for all entities that use certified software systems to issue invoices. Consequently, since nonresident VAT-registered entities will be required to use a certified software system effective 1 July 2021, in line with prior interpretation of this legislation and based on the PTA’s Frequently Asked Questions on this topic published on its website, it seems likely that nonresident entities will also have to comply with SAF-T obligations in Portugal effective 1 July 2021. However, this has not yet been confirmed nor clarified by the PTA and further information on this topic is expected.

Although further clarifications on this topic are expected, nonresidents who are registered for VAT in Portugal should start to take steps now to comply with their new invoicing and filing obligations in order to be prepared for implementation on 1 July.


For additional information with respect to this Alert, please contact the following:

Ernst & Young, S.A., Lisbon


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