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 from January 2023.

Table of contents

  1. What is the Portuguese SAF-T invoicing obligation?
  2. What are the invoicing SAF-T requirements?
  3. Difference between Portuguese accounting SAF-T and invoicing SAF-T
  4. What information must the SAFT-PT accounting file contain?

Portuguese SAF-T returns will be mandatory for foreign businesses by January 2023. 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 was already approved within the State Budget 2022.

Our certified billing software allows you to generate invoices and download your SAF-T file using a simple 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. During 2023, the Portuguese Tax Authorities tolerated in practice an extended deadline for SAF-T submission by the 8th day of the following month. However, from January 2024 onwards, the official deadline shall be respected, so SAF-T is due by the 5th day of the following month. Find here the official communication about the deadline.

What transactions are covered?

  • 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 issuing invoices with Portuguese VAT under an authorized billing software, you will also be liable to submit the SAF-T as from January 2023.
  • Special mention must be made to movements of own stock: following a conservative approach and in line with last invoicing regulations, deemed intra-Community supplies of goods from Portugal to other EU countries are also subject to certified billing and SAF-T reporting obligation. 

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).

In any case, please consider that a nil SAF-T is due and must be submitted. This is expected to be done through an additional functionality of the system. 

What are the invoicing SAF-T requirements?

To comply with the SAF-T obligation, you can choose between these two options for submission:

  • Activate your Portuguese certified billing software for the direct transmission of the monthly invoice reporting – SAF-T,
  • or upload manually the SAF-T file – previously extracted from the certified billing software via E-fatura portal.

If you do not have any invoices issued, you must also submit a monthly report confirming the absence of invoices via E-fatura portal.

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.

 What information must the SAFT-PT accounting file contain?

Reporting the accounting SAF-T is an obligation that only applies to taxpayers complying with corporate income taxes or personal income tax. Non-established companies do not have to submit accounting SAF-T.

The information that must be included in the SAFT-PT includes the following fields: article catalog, client and supplier list, VAT regimes, accounting movements, and accounts catalog. You can find the official FAQ here.

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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