Invoices will have to be issued through certified invoicing software by July 1, 2021, instead of January 1, 2021, as originally planned.

In order 412/2020, the Secretary of State for Taxes announced that the deadline for listing the unique code (ATCUD) on certain tax documents has been postponed to January 1, 2022. Therefore, this order has been suspended for 2022 and will not become mandatory until 2023.

B2G e-invoicing requirements in Portugal were recently delayed, including the requirement to sign e-invoices in PDF format, as follows:

  • January 1, 2022: Large companies
  • January 1, 2023: Micro, small and medium companies
Despacho351/2021.XXII was issued by the Secretary of State for Tax Affairs on November 10, 2021. Among the key items in the order are:
  • In 2022, the requirement to include an ATCUD (unique invoice ID) will be suspended and will become mandatory in 2023.
  • VAT returns due in the first semester must be filed by the 20th day of the month following the relevant tax period.
  • By June 30, 2022, all invoices must be submitted in PDF format.
Portugal published Ordinance 331-D/2021 on December 31, 2021, postponing the requirement to file the annual simplified business information return (IES/DA) before submitting the accounting SAF-T until 2023.

The Portuguese tax authority published Dispatch no. 49/2022-XXIII on May 24, 2022, extending deadlines for several tax obligations, including the deadline for accepting PDF invoices until December 31, 2022. A "Qualified Electronic Signature" (QES) will be required for all non-EDI invoices starting January 1, 2023. The Portuguese tax authority has extended this deadline several times in the past.

Portugal published its 2022 Budget Law (Orçamentodo Estado para 2022, Lei n.o 12/2022) on June 27, 2022. It introduces several important changes regarding the invoicing obligations of taxpayers:

  • Starting January 1, 2023, the deadline for the remittance of the invoicing SAFT-T file will change from the 12th to the 5th of the following month being declared.
  • Taxpayers will be allowed to deduct from income tax 120 percent of the expenses necessary for the implementation of the Accounting SAF-T and the unique code for documents (ACTUD), subject to the following conditions:
  • In the case of SAF-T accounting, the implementation of the system should be made before the end of fiscal year 2023;
  • The effective use of the ACTUD code in the invoices should be ready by January 1, 2023;
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