Portugal Overhauls the Periodic VAT Return: Portaria 298/2026/1 Brings VAT-Group Fields, Housing-Package Adjustments, and Pre-Filled Data

KGT Country Update | Portugal | July 23, 2026

On July 16, 2026, Portugal published Portaria n.º 298/2026/1 in Diário da República (No. 136/2026, Série I), amending Portaria 221/2017 and republishing the models and filling instructions of the periodic VAT return, Annex R, and the field 40/41 adjustment annexes.

The reform disaggregates several boxes (quadros 06, 06A–06D, and 20) to enable automatic pre-filling of taxable base and tax, adds fields for the new VAT-group regime, and operationalizes the Housing-Package reduced-rate adjustments. VAT-group and Housing-Package fields apply from July 1, 2026; the remaining changes take effect for tax periods beginning on or after July 1, 2027.

Background

Portugal's VAT reporting architecture — SAF-T (PT) billing files, ATCUD document codes, and certified invoicing software — already gives the tax authority (AT) transaction-level data. The redesign of the periodic VAT return is the next logical step: restructuring the return so that the AT can pre-fill taxable amounts and tax from the data it already receives, while accommodating two recent legislative innovations — the VAT group regime created by Lei n.º 62/2025 and the reduced-rate housing measures of Decreto-Lei n.º 97/2026 (the Pacote Habitação).

The Legislative Change

• Quadro 06 — box 24 is removed and new boxes 27, 28, and 29 split "other goods and services" by reduced, intermediate, and standard rate.

• Quadro 06A — new box 108 (acquisition of electricity from self-consumers) and box 109 ("other"), plus a new Part E for margin-scheme operations.

• New quadros 06B, 06C, and 06D — developing operations by rate, capturing active operations documented other than by invoice, and expanding box 8 of quadro 06.

• Quadro 20 — new fields for a substitute certified accountant under the "just impediment" rules.

• VAT groups — a dedicated field signals the election for the regime under Lei n.º 62/2025 (dominant entity holding, directly or indirectly, at least 75% of capital with more than 50% of voting rights for at least one year) and identifies the dominant company's NIF. Members still file individually; the dominant company confirms and pays the group total, with a minimum three-year commitment.

• Housing Package — new fields tie the reduced-rate regularizations to verba 2.42 of List I: a developer that paid standard-rate VAT during construction can recover the difference when a property is sold within the moderate-price limits; if the final price exceeds those limits, the buyer must remit the shortfall.

• Parallel changes flow through to Annex R and the field 40/41 adjustment annexes.

Scope

All taxpayers filing the Portuguese periodic VAT return are affected. The rate-split and margin-scheme disaggregation matters most for businesses with mixed-rate activity, and the group fields for corporate groups electing the new consolidation regime.

Timeline

• July 16, 2026 — Portaria 298/2026/1 published; in force the day after publication.

• July 1, 2026 — effective date for the VAT-group option fields and the Housing-Package (verba 2.42) adjustment fields.

• July 1, 2027 — the remaining restructured boxes apply for tax periods beginning on or after this date.

Businesses Affected

Multinationals with Portuguese entities should evaluate the VAT-group election, which allows consolidation of individually computed VAT balances and improves group cash flow. Real estate developers and housing buyers are affected by the verba 2.42 adjustment mechanics. Every business filing Portuguese VAT returns must eventually remap its return preparation to the new box structure.

Required Actions

• Assess whether a VAT-group election under Lei 62/2025 is advantageous and, if so, configure the new group-signaling and dominant-NIF fields (effective now).

• Map the new rate-split, margin-scheme, and non-invoice-documented operation boxes into SAP/ERP tax reporting well before the July 2027 cut-over.

• Audit e-invoice and SAF-T (PT) data classification: pre-filling is driven by the data the AT already holds, so misclassified transactions will surface as return discrepancies.

• Real estate businesses should implement the verba 2.42 adjustment processes on both the recovery and the buyer-shortfall side.

Practical Implications

Pre-filled returns shift the compliance burden upstream: the accuracy of the periodic return will increasingly depend on the accuracy of transaction-level e-invoicing and SAF-T data at the moment of issuance. Businesses with clean SAP tax determination will benefit from genuine simplification; those with classification weaknesses will face systematic reconciliation queries. The staggered timeline gives ERP teams a year for the structural changes — but the VAT-group and housing fields are already live.

Expected Next Steps

The AT is expected to publish updated electronic filing schemas and pre-filling specifications ahead of the July 2027 cut-over. KGT will report on the technical specifications and any guidance on the interaction between pre-filled data and taxpayer corrections.

How Can KGT Support You?

KGT supports multinationals running SAP in Portugal with SAF-T (PT) and certified-invoicing compliance, SAP-integrated e-invoicing add-ons, and SAP Document and Reporting Compliance (DRC) implementations. We can map the new return structure into your SAP tax reporting, audit the transaction-level data that will drive pre-filling, and model the cash-flow impact of a VAT-group election for your Portuguese entities.

Official sources

• Portaria n.º 298/2026/1 — Portal das Finanças (full text, PDF)

• Portaria n.º 298/2026/1 — Portal das Finanças legislative page

• Diário da República — Portaria 298/2026/1 of July 16, 2026 (No. 136/2026, Série I)

This publication is provided for general informational purposes only and does not constitute tax, legal, or professional advice. Please consult your advisor before acting on any information contained in this update.