Portuguese SAF-T mandatory for non-established businesses

Standard audit file for tax (SAF-T) will become mandatory for non-established company issuing invoices in Portugal, as per the draft State Budget proposal for 2022.

28 October, 2021


Portuguese SAF-T returns will be mandatory for foreign businesses. In harmony with the existing certified billing obligation, in place for non-established companies with a Portuguese VAT number and issuing invoices with Portuguese VAT since 1 July, 2021. The Portuguese SAF-T obligation will also be due for these non-established companies already complying with the authorized software obligation.

This obligation would be in line with the information currently available on the Frequently Asked Questions on SAF-T published by the Portuguese tax authorities, which include as subject to the SAF-T obligation the “taxpayers who carry out commercial, industrial or agricultural activities are required to produce the SAF-T (PT). This obligation also extends to taxable persons who use a certified invoicing program”. However, SAF-T was never confirmed to be due for non-established companies.

The measure is to be discussed and approved by the Portuguese Parliament as included in the draft State Budget 2022, nevertheless it shall be taken into account that due to political disagreements the Law proposal might not be approved, also it is expected that anticipated elections are summoned. If a new government needs to be established, we expect the SAF-T obligation to be postponed until further notice.

Our certified billing software allows you to generate invoices and download your SAF-T file using a simple our Excel template.

What is the Portuguese SAF-T invoicing obligation?

The SAF-T (that stands for Standard audit file for tax) is an internationally standardized file in XML format used to facilitate the treatment and exchange of tax information.

The Portuguese SAF-T submission is an obligation due on a monthly basis by the 5th day of each month, concerning all invoices issued with Portuguese VAT, and the file is generated by the authorized software used for the issuance of invoices – certified billing obligation. Please also consider that a nil SAF-T is due and must be submitted.

As previously indicated, SAF-T comes in hand with the certified billing obligation, therefore, if you are a non-established company registered for VAT in Portugal and you are already subject to the issuance of invoices with Portuguese VAT under an authorized billing software, you will also be liable to submit the SAF-T as from 2022.

Similarly, certain transactions are excluded from this obligation, including:

  • Invoices issued under reverse charge mechanism
  • Invoices issued for public events such as ticket for museums or shows, concerts (bearer documents)

Difference between Portuguese accounting SAF-T and invoicing SAF-T

Invoicing SAF-T for non-established businesses should not be confused with accounting SAF-T obligations.

An accounting SAF-T obligation requires a disclosure of all Portuguese accounting information, including your chart of accounts, your so called “taxonomías”, General ledger, master data of suppliers and customers and treasury information. It is an on-demand obligation, hence only needs to be submitted when requested by the tax authorities. Accounting SAF-T files are only due by established companies in Portugal. If you do not have physical presence in the country, you are normally not required to submit this obligation.

Invoicing SAF-T file includes information about issued invoices. It must be submitted periodically by all VAT registered businesses in Portugal (including foreign , non-established, companies once the new requirement enters into force). It is easier to comply with the invoicing SAF-T if you use a software that allows you to generate this file automatically.

How can we help you?

At Marosa we can assist you complying with the certified billing and SAFT obligation, as we have developed a Portuguese certified billing solution that already includes the monthly SAF-T production. So, acquiring our solution, they will be able to issue certified invoices according to Portuguese rules (hash, QR code and ATACUD) and the monthly SAF-T file (that also can be submitted to the tax authorities automatically).

Marosa’s certified billing solution for Portugal is a web-based tool that receives invoices to be certified both manually (over a web-form) and automatically (via sFTP or webservice). In both cases, our invoicing process is simple: i) filing of our Excel file template with the invoice data ii) submission through our tool. Once the file has been submitted all invoices will be issued according to Portuguese rules, with the following main features:

  • Excel file from our pre-defined template.
  • Non-invasive set-up. No ERP changes or configuration needed.
  • Batch submission (the excel file can have one invoice or multiple invoices).
  • Automatic mailing of certified invoices to both customer and issuer email accounts in PDF format.
  • Certified invoices can be downloaded from our tool in bulk.
  • Customizable PDF invoice (your own logo, bank payment details, details, remarks, etc.).
  • QR code generation according to Despacho n.º 412/2020.XXII, that will be mandatory from January 2022.
  • Monthly SAF-T file generation.

Get in touch

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