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Obligation of using a certified invoicing program

Obligation of using a certified invoicing program by non-established taxable persons with a VAT registration in Portugal


From 1 July 2021 onwards, non-established taxable persons with a VAT registration in Portugal, are obliged to issue invoices through invoicing programs previously certified by the Portuguese Tax Authority.

This obligation, generically created by Decree-Law No. 28/2019, of 15 February, has been successively postponed, with the last postponement having coincided with the entry into force of the VAT package for e-commerce, which enters into force on 1 July 2021. Although some Member States have requested further postponement of the entry into force of this package, this is not expected to happen. Consequently, as of July 1, 2021, taxable persons not established with a VAT registration in Portuguese territory are obliged to: 1. Issue invoices and other documents relevant for tax purposes through the exclusive use of computer programs previously certified by the Portuguese Tax Authority, in accordance with legal requirements; 2. Ensure compliance with legal requirements in the processing of invoices and other documents relevant for tax purposes, namely: (i) date and sequential numbering; (ii) identification of the supplier and the acquirer; (iii) quantity and name of the goods or services provided; (iv) price net of tax, applicable fees and amount of tax due; (v) reason for not applying the tax, if applicable; (vi) four characters of the digital signature; (vii) number of the certified invoicing program; (viii) only applicable from January 1, 2022, onwards but with the possibility of application from now on, inclusion a two-dimensional barcode (QR code) and a unique document code (ATCUD). The list of invoicing computer programs already certified by the Portuguese Tax Authority may be seen at https://www.portaldasfinancas.gov.pt/pt/consultaProgCertificadosM24.action.

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