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Portugal non-residents: certified invoice; SAF-T Billing; QR Code from January 2023

Much postponed requirements on non-resident VAT registered business come into effect 1 January 2023

The Tax and Customs Authority (AT) is to require foreign businesses VAT registered in Portugal to comply with 3 requirements already in place for residents:

  • Invoices must be produced by certified invoicing software that can allocate a unique ATCUD code;
  • Paper or PDF invoices must include a QR Code; and
  • Monthly invoice reporting via SAF-T Billing file (other options, see below).

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Note, this is separate from the new annual SAF-T Accounting reporting requirement. See Portugal SAF-T full requirements.

1. ATCUD Sequential Number Validation Code number

A unique 8-digit code, ATCUD, is allocated by AT for batches of invoices prior to their issuance. It is made up of two parts, separated by “-“:

  • Service validation code; and
  • Unique document code within the batch numbers issued.

ATCUD codes are processed on certified billing systems with batches numbers sourced via AT on an API call. These are held by the system and allocated as the invoice is created.

2. QR code for paper or PDF invoices

This is a two-dimensional bar code – quicker to read by IT systems and holds more data than the traditional barcode. However, the QR code may be bypassed for taxpayers using electronic data interchange (EDI), for the intercompany communication of business documents in a standard format. Most of the fields need to be linked (or ‘mapped’) using SAF-T.

The code contains the following data:

  • Supplier tax identification number (TIN)
  • Unique UIDD or ATCUD number for the invoice (see below)
  • Taxable amount
  • VAT amount
  • Certified software unique number.

3 Monthly SAF-T Billing submissions

From 1 January 2023, non resident will have to report their invoices to AT. This can be directly to AT via manual interface or webservice. But a third option, monthly SAF-T Billing is the simplest and most popular option. This is produced by certified billing providers.

It must be filled by the 5th of the month following the transaction period.

Portugal SAF-T was introduced in 2009, based on OECD SAF-T standard data exchange regime.

SAF-T Billing is structured as follows:

  • Master files: product tables; customers; suppliers; and tax table
  • Transaction data: sales and purchase invoices; goods movements; payment information

This information is only obliged when readily available in the taxpayers accounting systems.

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