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Portugal Regulatory Updates April 2024

Hatice Ozcan

Apr 30, 2024

Portugal's Tax Authority Launches CESOP Filing Tools for PSPs Ahead of Deadline


With the remaining until the statutory deadline for submitting the inaugural CESOP file in Portugal, the Tax Authority (AT) has now equipped Payment Service Providers (PSPs) with the necessary registration and file submission tools on the Finance Portal. This update enables PSPs to fulfill their CESOP reporting duties on time.


Law No. 81/2023, enacted on December 28, incorporates EU Directive 2020/284 into Portuguese law, mandating that Payment Service Providers (PSPs) maintain detailed records of specific cross-border payments. This data is to be reported periodically to the Tax Authority (AT) and then uploaded to the Central Electronic Payment Information System (CESOP), a pan-European database designed to facilitate the joint processing of data by EU Member States to combat VAT-related tax fraud.

PSPs in Portugal are required to submit CESOP files by the end of the month following each quarter, with the initial report due by April 30, 2024. Despite the approaching deadline, PSPs have experienced some anxiety due to operational delays in the Finance Portal's registration and file submission functionalities, which were only resolved mid-last week.

The registration process for PSPs on the Finance Portal mirrors that of other information exchange systems, like DAC2/CRS and DAC7. PSPs without a Portuguese tax identification number (NIF) do not need one to register and submit CESOP files; the AT will provide the necessary credentials during registration. Files can be submitted through the portal or via Webservice for those with a Portuguese NIF.

PSPs are advised to submit an "empty" file if no reportable payment services are provided in a period, a mandatory procedure that differs from other regimes. As there is no anticipated extension for the first CESOP filing, PSPs must ensure timely registration and compliance with specific technical requirements, such as the 40,000 transaction limit per XML file, to avoid submission errors.

This complex compliance framework underscores the importance for PSPs to not only meet the regulatory deadlines but also ensure that their submissions adhere to the stipulated requirements to avoid future validation issues by the AT.

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