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Portugal non-residents certified digital invoice; QR code; SAF-T billing

3 reforms for non-resident taxpayers implemented 1 January 2023

Since 1 January 2023, the  Tax and Customs Authority (AT) now requires 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

Non residents  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.

Europe e-invoicing and live reporting

Country Date Comments (click for details)
EU e-invoice proposals 2028 Digital reporting and e-invoicing harmonisation
Albania Jan 2021 Authorised e-invoice software and pre-clearance
Belgium 2026? Phased introduction of B2B e-invoices
Bulgaria TBC Public consultation on pre-clearance model e-invoice
Croatia 2025 B2B mandatory e-invoicing
Denmark 2024 Digital record keeping obligations
Finland Apr 2020 Customer option to require B2B e-invoices
France Mar 2026 E-invoicing and e-reporting for B2B and B2C
Germany Jan 2026 B2B mandatory e-invoicing proposals
Greece 2025 e-invoicing based on exiting myDATA digital reporting
Hungary Jul 2018 RTIR live invoice reporting. No govt pre-clearance required
Jan 2024 eVAT pre-filled returns based on live invoice reporting
Italy Jan 2019 Pre-clearance SdI e-invoicing
Ireland TBC Public consultation underway
Latvia Jan 2025 B2B e-invoices based on PEPPOL
Lithuania ? E-invoicing platform being scoped
Netherlands No mandate planned Unlikely to adopt domestic reforms
Poland Jul 2024 B2B mandated e-invoicing
Portugal Jan 2024 Certified invoicing software for non-residents
Jan 2024 ATCUD digital invoice signature for non-residents
Romania Jul 2024 RO e-invoicing implementation
Russia TBC Extension of Traceability Model to B2B on hold
Serbia Jan 2023 B2B e-invoicing
Slovakia 2025 B2B and B2C e-invoice rollout
Slovenia 2025 ? e-SLOG B2B proposal stalled
Spain 1 Jul 2017 SII live invoice and book reporting
Spain 2 2025? Pre-clearance B2B e-invoices; supplement to SII
Sweden TBC PEPPOL based mandatory e-invoicing
Turkey Jan 2014 e-invoice e-Fatura and e-Arşiv
UK Apr 2022 MTD for VAT extended to 1.1million taxpayers


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