Portugal has issued detailed instructions for the VAT Group Regime declaration, covering submission procedures, tax calculations, refunds and rectifications.

RF Report

Portugal published Ordinance No. 244/2026/1 in its Official Gazette on 1 June 2026, approving the VAT declaration (return) form and accompanying instructions for the newly introduced VAT Group Regime (Regime de Grupos de IVA). The ordinance establishes the official model and guidance for the new VAT Group Regime Declaration, under which businesses with financial, economic, and organisational links may consolidate their VAT balances and submit a single group VAT return.

Below is a detailed summary of the declaration form and the associated rules

Overview and effective date

The new reporting requirements apply to tax periods beginning on or after 1 July 2026, including the third quarter of 2026. While each member of the VAT group continues to calculate its tax individually, the dominant entity is responsible for submitting the consolidated group declaration.

Submission and deadlines

  • Automatic generation: The Tax and Customs Authority (AT) pre-fills the group declaration on the Finance Portal by aggregating the data from each member’s individual periodic returns.
  • Confirmation: The dominant entity must confirm the declaration within the legal deadline.
  • Automatic submission: If the dominant entity fails to confirm the declaration by the deadline, the system will automatically convert it into a submitted return.
  • Rectifications: Any later changes to individual member returns—whether initiated by the taxpayer or the AT—will automatically trigger a rectification of the group declaration.

The VAT group declaration form (Structure)

The declaration is divided into five main sections, known as “Quadros”:

Quadro 1 & 2: Identification

  • Quadro 1: Records the Tax Identification Number (NIF) and the name of the dominant entity.
  • Quadro 2: Identifies the tax year, the specific reporting period, and whether the declaration is being submitted within the legal timeframe.

Quadro 3: group tax calculation

This section is entirely auto-populated using data from the individual VAT returns of every group member. For each entity, the following fields are tracked:

  • Field T1 (Prior Excess): This represents tax credits from before joining the group (first period) or carried over from the previous group return (subsequent periods). Use of this credit is limited; it can only offset the specific tax debt (Field B) of the entity that generated it.
  • Field A & B: These reflect the tax in favour of the taxpayer (Field 91 of individual returns) and tax in favour of the State (Field 92 of individual returns).
  • Field C (Entity Net Balance): The individual result for each entity after accounting for T1 credits and Fields A and B.
  • Field T2 (Carried Forward Individual Excess): Any portion of a T1 credit that could not be used in the current period because it exceeded the entity’s tax debt.
  • Fields D, E, & F: These calculate the total group position by summing all individual balances (Field D), subtracting any group-level credits from the previous period (Field E), and arriving at the final total (Field F).

Quadro 4: group tax outcome

Depending on the result in Field F, the group will either owe tax or have a credit:

  • Field G (Tax to Pay): Used if the group has a positive tax balance.
  • Field H (Refund Request): If the group has a credit (negative balance), the dominant entity can request a full or partial refund. Note: Refunds cannot be requested if the declaration is submitted late.
  • Field I (Excess to Carry Forward): Any credit not claimed as a refund is carried over to the next tax period.

Quadro 5: mode of submission

This final section is also auto-populated to indicate how the declaration was finalised:

  • Confirmed by Accountant: If the dominant entity’s certified accountant confirms the return, their NIF is recorded here.
  • Automatic Conversion: If the deadline passed without confirmation or if changes were made to individual returns, the form will indicate it was “automatically converted”

Earlier, Parliament approved a VAT Group regime under Law No. 62/2025, effective from 1 July 2026, with parents managing VAT and members jointly liable.