Country Updates

Portugal Introduces Important Changes to Invoice Reporting Obligations and E-invoicing Beginning in 2023

Portugal Introduces Important Changes to Invoice Reporting Obligations and E-invoicing Beginning in 2023

The Portuguese Secretary of State for Tax Affairs has signed a Government Order that makes significant changes to the format of e-invoices and digital tax reporting responsibilities for taxpayers.

The State Order has extended the deadline for mandatory usage of Qualified Electronic Signatures (QES) for invoices and decreased the time frame for the mandatory transfer of invoice transactional data to the Tax Authority. Moreover, the Tax Authority is also planning to introduce a tax alert system. This system will send communications to support compliance for taxpayers who do not report the invoice transactional data within the prescribed deadline. 

Timeline and Impact

Let’s take a closer look at the details of the Government Order:

  • The period during which the use of QES for invoicing is optional (rather than mandatory) has been extended to December 31, 2023. Until then, PDF invoices will be treated as e-invoices.
  • The period for mandatory transmission of invoice transactional data to the Tax Authority (which must be sent the month after the invoice has been issued) has been shortened from 12 days to 5 days beginning in 2023.
  • The Tax Authority’s introduction of the tax alerting system is planned for 2023. The transmission of invoicing data will be extended without the application of penalties until the 8th day of the following month of the invoice issuance date.
  • The Economic Operators are allowed to communicate inventories to the Tax Authority for 2022 until February 28th, 2023, or until the end of the second month following the end of the tax period, without any penalties.

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