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SAF-T Process in Portugal

Updated: Feb 6

Portuguese SAF-T mandatory for non-resident businesses Standard audit file for tax (SAF-T) will become mandatory in Portugal, as per the State Budget proposal for 2022. Portuguese SAF-T returns will be obligatory for all companies. In this situation with the existing, 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-resident companies already complying with the authorized software obligation.


What is the SAF-T Portugal file?


SAF-T (PT) (Standard Audit File for Tax Purposes — Portuguese version) is a standardized file (in XML format) to allow an easy export, at any time, of a predefined set of accounting and invoicing records or equivalent, in a readable and common format, independent of the program used, without affecting the internal structure of the program’s database or its functionality. The adoption of this model provides companies with a tool that allows them to satisfy the requirements for obtaining information from inspection services, simplifying procedures and encouraging the use of new technologies. The generation of the file by the information systems always covers a certain annual tax period, in whole or in part.


SAF-T must be manufactured on a computer system approved by the Portuguese Tax and Customs Administration (Autoridade Tributária e Aduaneira — AT). It must be declared through public network services. The invoice to be sent to the customer must contain the SAF-T file and a unique code received with the response from AT. This code includes the signature of the previous invoice so that invoices are guaranteed one after the other.


Since 2013 the SAF-T Portugal Edition (PT) file was also used as the basis for the regular submission of invoicing and logistics data to the tax authorities by taxpayers (via the e-invoicing website). The SAF-T (PT) file intends to facilitate gathering relevant tax data in electronic form by tax inspectors to aid taxpayers’ tax returns and analyze accounting records. In this regard, the SAF-T (PT) document requires an XML structure. There is no specific format for invoice status. Interested parties can agree to use existing standards (EDIFACT, X12, XML).


SAF-T must be manufactured on a computer system approved by the Portuguese Tax and Customs Administration (Autoridade Tributária e Aduaneira — AT). It must be declared through public network services. The invoice to be sent to the customer must contain the SAF-T file and a unique code received with the response from AT. This code includes the signature of the previous invoice so that invoices are guaranteed one after the other.


It is possible to summarize how SAF-T (PT) works: sales invoices (documentos comerciais a clientes), transport documents (documentos de transporte), and customer payments are recorded directly in the accounting system. A standard SAF-T (PT) file in XML format is created from the data processed in the accounting system. This file is the source for the tax return. Sales transmit to AT via the finance portal (Portal das Finanças). Transport documents (transport documents: Guia de Remessa, Guia de Transporte, invoice) are sent to AT after a standard SAF-T (PT) file has been created in XML format.


What are the benefits of the SAF-T Portugal?


The purpose of the SAF-T (PT) file is to facilitate the collection of relevant tax data from taxpayers in electronic format by tax inspectors/auditors in support of tax returns and/or for analysis of accounting records or others. Thus, the financial reporting obligation is fulfilled.

The term of SAF-T Portugal, as a general rule, covers a full financial year. Concerning the creation of a SAF-T (PT) with accounting records, it will be mandatory to include the entire fiscal year in one file. According to Annex I of Regulation 302/2016, it is exceptionally possible to generate SAF-T (PT) invoice files only for full monthly periods due to technical reasons regarding the size of commercial document tables.


Accounting SAF-T in Portugal


Accounting SAF-T (PT) must be created in a single file. The new accounting practice will have to ensure that the SAF-T (PT) is produced with the records made in the previous practice, even if new references and terminologies and postings are notified. The transfer of records to a new accounting program at a time that does not coincide with the beginning of the accounting period cannot be made by transferring the balance alone.


It is the software manufacturer’s responsibility to create other fields of the SAF-T (PT) file with the structure specified in Regulation №2, which are not specified, belong to the same structure and contain information that must be filled in the pool. The user should be prohibited from making any choices about whether or not a particular transaction or record should be included in the SAF-T (PT) file.


Not all fields are considered forced rendering in a validation scheme, as there are some alternative selection fields and other fields whose generation may not make sense in a particular context. For example, if no discount is assigned, it’s not about requiring the “Line discount amount” (Attach Amount) field to be filled.


Likewise, fields that are not specified as mandatory should not be created when there is no information in the warehouse to fill in. This procedure reduces the time and size of the file to be created. Also, there cannot be empty fields in SAF-T (PT) under penalty for violating the validation scheme.

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