Portuguese VAT return due date extended and ATCUD invoicing requirement delayed

As part of the continuous COVID-19 pandemic measures published by the Portuguese tax authorities, they confirmed new deadline extensions for VAT returns, and the postponement of the ATCUD invoicing requirement.


Portuguese VAT returns will benefit from extended deadlines to be submitted. The implementation date for the ATCUD requirement on invoices was also postponed.

Following the previous COVID simplifications, Portuguese authorities announced the new VAT return submission and payment deadlines for the reporting periods from September 2021 to April 2022, as well as the postponement of the ATCUD requirement – which was expected to enter into force by January 2022.

New VAT return deadlines in Portugal

The new deadlines for the VAT returns submission in Portugal are the following:

  • Monthly reporting periods from September 2021 to April 2022: the submission of these VAT returns will be due by the 20th day of the second month following the reporting period. For example, the September 2021 VAT return must be submitted by the 20 November.
  • Quarterly reporting periods from Q3 2021 to Q1 2022: the submission of these VAT returns will be due by the 20th day of the second month following the reporting period.

If the deadline falls in a weekend or non-working day, the deadline is extended to the next working day.

The new deadlines for making the correspondent VAT payments in Portugal are the following:

  • Reporting periods September 2021 and Q3 2021: the deadline for the VAT payment is extended to 30 November 2021.
  • Reporting period October 2021: the deadline for the VAT payment is extended to 30 December 2021.
  • Reporting periods November and December 2021, Q4 2021 and Q1 2022: the deadline for the VAT payment is extended to the 25th day of the second month following the reporting period.

If the deadline falls in a weekend or non-working day, the deadline is extended to the next working day.

These deadlines were already changed in the past. In our previous article, you can check the applicable standard VAT return deadlines in Portugal for submission and payments.  

You may also take into account that international bank transfers take several days to arrive to the bank account of destination. The VAT amounts must arrive to the tax authorities’ bank account within the deadline for VAT payment.

Postponement of the ATCUD requirement on invoices

The ATCUD – Código Único de Documento, requirement for Portuguese invoices was postponed again. It was expected to enter into force in January 2022, but the Portuguese tax authorities have recently announced the suspension of this requirement during 2022.

It is possible to already start including the ATCUD in the Portuguese invoices, but it will not be a mandatory requirement for the moment.

Also, the PDF invoices will be accepted until 30 June 2022 – as announced in the same public order.

Our solution on Portuguese certified invoices

Portugal requires all businesses to issue certified invoices. This obligation applies to non-established businesses also. Marosa developed a web-based solution allowing these businesses to simply generate their certified invoices without requiring a complex integration with their ERP.

Marosa´s certified billing tool generates invoices meeting all requirements in Portugal, including the QR code and upcoming ATCUD obligation. You can generate these invoices from an Excel file or sending a CSV file via SFTP directly from your billing system.

You will find more information about our solution under the following link

Get in touch

Contact Marosa to book a demo of our tool with our of our tax technology experts.

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