Introduction to the Periodic VAT Return

The Periodic VAT Return (DP IVA) is a fundamental pillar of the Portuguese tax system, representing the fulfilment of one of the most recurrent tax obligations for most companies and liberal professionals. This document not only informs the Tax and Customs Authority (AT) about taxable operations carried out in a given period but also serves as the basis for calculating the tax due or the credit in favour of the taxpayer. Its correct and timely submission is crucial to avoid fines and late payment interest that can significantly burden economic activity.

Since the entry into force of Decree-Law No. 49/2025, which substantially altered the VAT Code, the deadlines and rules surrounding the periodic return have been harmonised and simplified. Understanding these new provisions is essential to ensure tax compliance and sound financial management for any entity.

This article, updated for 2026, aims to demystify the deadlines, regimes, and obligations associated with the Periodic VAT Return, offering a comprehensive and practical guide for taxpayers, accountants, and entrepreneurs. We will address the tax regimes, the tax calendar, common errors, and the consequences of non-compliance, always focusing on current legislation and optimising tax management.

Monthly or Quarterly Regime: Which One Applies to You?

The periodicity of submitting the Periodic VAT Return depends essentially on the taxpayer's turnover in the previous calendar year. This distinction is crucial for tax planning and for managing companies' cash flow.

It is important to note that opting for the monthly regime, even for those who would fall under the quarterly regime, is permitted and can be advantageous in certain circumstances. This option must be communicated to the Tax and Customs Authority, usually in the declaration of commencement of activity or alteration. One of the main reasons for opting for the monthly regime is the acceleration of the VAT refund process, particularly for companies that are structurally in a tax credit situation. This occurs, for example, in exporting companies or those making significant investments.

Taxpayers covered by the VAT exemption regime under Article 53 of the CIVA are generally not obliged to submit the Periodic VAT Return, as they neither charge nor deduct tax. However, there are exceptions, such as intra-Community transactions, which may require the submission of specific returns, such as the recapitulative statement.

The Rule of Deadlines: 20th and 25th Day

Following the reformulation of Article 41 of the VAT Code by Decree-Law No. 49/2025, effective from 1 July 2025, the deadlines for submitting the Periodic Return and for paying VAT have been simplified and unified for both monthly and quarterly regimes. This change brought greater clarity and predictability to the tax calendar.

• Submission of the return: The Periodic VAT Return must be submitted electronically on the Tax Portal by the 20th day of the 2nd month following the month or quarter to which the operations relate.
• Payment of the calculated VAT: The tax resulting from the periodic return, whether payable or receivable (in the case of a refund), must be settled by the 25th day of that same month. This provision is expressed in Article 27 of the CIVA.

It is essential that taxpayers and their accountants update their calendars and control systems, as the old deadlines of the 10th and 15th have been eliminated. Failure to adapt to these new deadlines can lead to non-compliance and the application of fines.

An important rule to consider is the transfer of deadlines: when the 20th or 25th day coincides with a weekend or a public holiday, the deadline is automatically extended to the next working day. This flexibility is an aspect to consider in planning and managing submission and payment deadlines.

VAT Calendar 2026: Schemes for Quarterly and Monthly Regimes

To facilitate understanding and planning, we present the detailed calendars for both tax regimes in 2026, already adjusted for weekends and public holidays.

VAT Calendar 2026 — Quarterly Regime

This regime applies to most small and medium-sized enterprises in Portugal, with turnovers below €650,000.

VAT Calendar 2026 — Monthly Regime

For taxpayers with a higher turnover, the periodicity is monthly, requiring more constant and careful management. The logic of the deadlines is the same: operations for month M are declared by the 20th of month M+2 and paid by the 25th of that same month.

• VAT for December 2025 → submission by 20 March 2026, payment by 25 March 2026;
• VAT for January 2026 → submission by 20 March 2026, payment by 25 March 2026;
• VAT for February 2026 → submission by 20 April 2026, payment by 25 April 2026;
• VAT for March 2026 → submission by 22 May 2026, payment by 25 May 2026 (adjusted);
• VAT for April 2026 → submission by 20 June 2026, payment by 25 June 2026;
• VAT for May 2026 → submission by 20 July 2026, payment by 25 July 2026;
• VAT for June 2026 → submission by 20 September 2026, payment by 25 September 2026 (August deadline shifts due to tax holidays);
• VAT for July 2026 → submission by 20 September 2026, payment by 25 September 2026;
• VAT for August 2026 → submission by 20 October 2026, payment by 25 October 2026;
• VAT for September 2026 → submission by 20 November 2026, payment by 25 November 2026;
• VAT for October 2026 → submission by 20 December 2026, payment by 25 December 2026;
• VAT for November 2026 → submission by 20 January 2027, payment by 25 January 2027;
• VAT for December 2026 → submission by 22 February 2027, payment by 25 February 2027 (adjusted).

It is crucial that the taxpayer or their accounting firm always confirms the official tax calendar made available annually on the Tax Portal, as there may be occasional adjustments or municipal holidays that affect deadlines.

August Tax Holidays and Impact of Public Holidays

The Portuguese tax system provides for some flexibility in the deadlines for fulfilling tax obligations, namely "tax holidays" and the extension of deadlines in case of public holidays or weekends.

August Tax Holidays

One of the best-known and appreciated rules by taxpayers concerns the so-called "tax holidays". According to Article 57-A of the Tax Procedure and Process Code (CPPT), deadlines for tax acts that end in August are extended to the first working day of the following month. In the context of the Periodic VAT Return, this means that the return whose submission deadline would end in August can be fulfilled without penalties until 20 September, and payment until 25 September. This rule applies to both the monthly regime (June VAT) and the quarterly regime (2nd quarter VAT).

This flexibility is a permanent measure aimed at alleviating pressure on companies and accounting professionals during the summer holiday period, recognising the decrease in activity and the difficulty in gathering the necessary documentation.

Impact of Public Holidays and Weekends

In addition to tax holidays, legislation provides that whenever the final deadline for submitting a return or paying a tax coincides with a non-working day (Saturday, Sunday, or public holiday), it is automatically extended to the next working day. This rule is implicit in Article 279 of the Civil Code, which applies subsidiarily to tax law.

Practical example: if 20 May is a national holiday or a Saturday/Sunday, the deadline for submitting the Periodic VAT Return for the 1st quarter of 2026 (or for March for the monthly regime) will be extended to the immediately following working day, which in the calendar example above, would be 22 May. The same applies to the payment deadline if the 25th falls on a non-working day.

Attention to these details is fundamental to avoid involuntary delays and their respective penalties. Regular consultation of the official AT tax calendar is a recommended practice.

Practical Examples of VAT Calculation

To illustrate the VAT calculation process, let's consider two typical scenarios, one for the quarterly regime and another for the monthly regime.

Example 1: Company under the Quarterly Regime (1st Quarter of 2026)

The company "Soluções Digitais Lda.", which provides IT consulting services, is under the quarterly regime. In the 1st quarter of 2026 (January to March), it recorded the following operations:

• Services provided to clients in Portugal: €25,000 (VAT at the standard rate of 23%)
• Services provided to clients in other EU Member States (with valid NIF): €10,000 (exemption due to reverse charge, Art. 6 of the CIVA)
• Acquisition of goods and services with deductible VAT:
  • Office consumables: €500 + VAT (23%)
  • Office rent: €1,000 + VAT (23%)
  • Telecommunications services: €200 + VAT (23%)
  • Computer acquisition (investment good): €1,500 + VAT (23%)

Calculation of Output VAT:

• Services in Portugal: €25,000 x 23% = €5,750
• Intra-EU services: €0 (exemption)
• Total Output VAT: €5,750

Calculation of Input VAT:

• Office consumables: €500 x 23% = €115
• Office rent: €1,000 x 23% = €230
• Telecommunications services: €200 x 23% = €46
• Computer acquisition: €1,500 x 23% = €345
• Total Input VAT: €115 + €230 + €46 + €345 = €736

VAT Calculation:

VAT Payable = Output VAT - Input VAT

VAT Payable = €5,750 - €736 = €5,014

The company "Soluções Digitais Lda." must submit the Periodic VAT Return by 22 May 2026 and make the payment of €5,014 by 25 May 2026.

Example 2: Company under the Monthly Regime (January 2026)

The company "Manufacturas Têxteis S.A.", with a turnover exceeding €650,000, is under the monthly regime. In January 2026, it recorded the following:

• Sale of textile products in the national market: €80,000 (VAT at the standard rate of 23%)
• Export of textile products outside the EU: €30,000 (exemption with right to deduction, Art. 14 of the CIVA)
• Acquisition of raw materials: €40,000 + VAT (23%)
• Advertising services: €2,000 + VAT (23%)

Calculation of Output VAT:

• National sales: €80,000 x 23% = €18,400
• Exports: €0 (exemption)
• Total Output VAT: €18,400

Calculation of Input VAT:

• Raw materials: €40,000 x 23% = €9,200
• Advertising services: €2,000 x 23% = €460
• Total Input VAT: €9,200 + €460 = €9,660

VAT Calculation:

VAT Payable = Output VAT - Input VAT

VAT Payable = €18,400 - €9,660 = €8,740

The company "Manufacturas Têxteis S.A." must submit the Periodic VAT Return for January 2026 by 20 March 2026 and make the payment of €8,740 by 25 March 2026.

Common Errors in the Periodic Return and How to Avoid Them

The complexity of the CIVA and the recurring nature of this tax obligation can lead to frequent errors, with significant tax and financial consequences. It is essential to be aware of the most common mistakes to avoid them.

• Failure to submit a "nil" return: One of the most basic, yet recurrent, errors is the omission of submitting the periodic return for periods with no purchases or sales. Even if there are no taxable operations, the obligation to submit the return remains, and it must be submitted with zero values. Failure to submit, even a "nil" return, constitutes a tax infraction punishable by a fine, as per Article 116 of the General Regime of Tax Infractions (RGIT).
• Discrepancies with e-Fatura and SAF-T: The Tax and Customs Authority (AT) has increasingly sophisticated data cross-referencing systems that compare information from the Periodic Return with data from e-Fatura and SAF-T files (Standard Audit File for Tax). Inconsistencies in taxable bases or in output/input VAT between these documents are quickly detected and can lead to requests for clarification, tax inspections, and the application of fines. It is crucial that accounting records are aligned with invoices issued and received.
• Deducting VAT from documents without legal form: The deduction of VAT is a right of the taxpayer, but it is only permitted if the tax is stated on invoices or equivalent documents that comply with all legal requirements set out in Article 36 of the CIVA. Invoices with an incorrect NIF, without clear identification of the goods or services, or issued by taxpayers not registered for VAT purposes, do not confer the right to deduction. Improper VAT deduction is one of the main causes of corrections during inspections.
• Ignoring reverse charge (self-assessment): In certain operations, such as in civil construction (subcontracting, as per Article 2, No. 1, paragraph i) of the CIVA) or in intra-Community acquisitions of goods and services, the responsibility for paying VAT falls on the acquirer of the goods or services, and not on the supplier. This mechanism, known as "reverse charge" or "self-assessment", requires the completion of specific fields in the Periodic VAT Return (Fields 3 and 4 for intra-Community acquisitions of goods, and Fields 16 and 17 for self-assessment of services or goods). Omission or incorrect completion of these fields can lead to double taxation or failure to pay due tax.
• Forgetting the Recapitulative Statement for intra-Community operations: For taxpayers who carry out intra-Community supplies of goods or services to other European Union (EU) Member States, there is an obligation to submit the Recapitulative Statement (Model 32). This statement is independent of the Periodic VAT Return and serves to feed the VIES system (VAT Information Exchange System), allowing for the control of cross-border operations. Its omission is easily detected by automatic data cross-referencing between European tax administrations and is punishable by a fine under Article 117 of the RGIT.
• Requesting a VAT refund without the required annexes and requirements: The request for a VAT refund, regulated by Article 22 of the CIVA, requires compliance with formal requirements and the submission of specific annexes (such as Annex R for investment goods). The lack of annexes, errors in completion, or non-observance of legal requirements can significantly delay the tax refund process, sometimes for several months, impacting the company's cash flow.
• Confusing special VAT regimes: There are special VAT regimes, such as the Cash Accounting VAT Regime or the Small Retailers regime, which have their own rules for calculation and submission deadlines. The incorrect application of a regime to a taxpayer who does not meet the requirements can lead to serious tax inaccuracies.

Attention to these points, the use of updated accounting software, and review by a qualified professional (Certified Accountant) are the best strategies to minimise the occurrence of these errors.

Recapitulative Statement: The Essential Obligation in Intra-Community Operations

The Recapitulative Statement, also known as Model 32, is a tax obligation of extreme importance for taxpayers who carry out intra-Community operations. It is not a VAT return in the traditional sense of tax calculation, but rather a control and information-sharing tool between the tax administrations of the European Union Member States.

What is it and What is it For?

The Recapitulative Statement reports intra-Community supplies of goods and services provided to taxpayers in other Member States, as well as intra-Community acquisitions of goods. Its main objective is to feed the VIES system (VAT Information Exchange System), which allows tax administrations to verify the validity of VAT identification numbers of economic operators and control the movement of goods and services within the EU. This statement is fundamental for the correct application of the exemption regime for intra-Community supplies of goods (Article 14 of the VAT Regime for Intra-Community Transactions - RITI) and for the reverse charge mechanism for services.

Who is Obliged?

Taxpayers registered for VAT purposes in Portugal (with a PT VAT ID) who:

• Carry out intra-Community supplies of goods (sales to other EU countries);
• Provide services to taxpayers in other Member States, when the place of taxation is that of the recipient (general rule, B2B);
• Carry out intra-Community acquisitions of goods (purchases from other EU countries), if registered for this purpose.

Even taxpayers exempt under Article 53 of the CIVA may be obliged to submit the recapitulative statement if they carry out intra-Community operations that require them to have a VAT ID for VIES purposes.

Submission Deadlines

The Recapitulative Statement must be submitted electronically by the 20th day of the month following that in which the operations occurred. However, there is an option for quarterly periodicity for taxpayers who do not exceed certain limits of intra-Community operation volume. This option must be communicated to the AT.

Omission or incorrect completion of the Recapitulative Statement is a serious tax infraction. The AT quickly detects these failures by cross-referencing data with the declarations of commercial partners in other Member States. Fines for non-submission or late submission of the recapitulative statement are provided for in Article 117 of the RGIT.

For companies operating in the European market, the Recapitulative Statement is not a mere formality, but an integral part of their monthly or quarterly tax routine. Its correct management ensures compliance and avoids problems with tax authorities, both national and European.

In HVR accounting packages (from €150/month — see prices), periodic and recapitulative statements are prepared, validated against e-fatura, and submitted on time, with prior notice of the amount to be paid, ensuring your tax peace of mind.

Fines and Interest for Delay: The Consequences of Non-Compliance

Delay or omission in fulfilling VAT tax obligations can lead to significant financial penalties, including fines and late payment interest. It is essential to understand the sanctioning framework to grasp the importance of punctuality and rigour in tax management.

• Late return or omission of submission: Failure to submit the periodic return or its submission outside the legal deadline is punishable by a fine of €150 to €3,750, as per Article 116 of the General Regime of Tax Infractions (RGIT). For legal entities, the amounts tend to be higher, with the minimum fine potentially being €300. The severity of the fine may increase in case of recurrence or if the omission is detected by the AT before voluntary regularisation by the taxpayer.
• VAT not paid to the State (failure to pay): If, in addition to late submission, there is calculated and unpaid tax, the fines are more severe. Failure to pay due VAT within the legal deadline is punishable by a fine between 15% and 50% of the outstanding tax, in cases of negligence. If intent (intention not to pay) is proven, the fine can reach double the outstanding tax, with a maximum limit of €165,000, according to Article 114 of the RGIT.
• Late payment interest: In addition to fines, overdue tax is subject to late payment interest. The rate of late payment interest is set annually by order of the Minister of Finance and applies to the amount of tax due, calculated for each day of delay. The applicable rate for 2026 will be defined, but historically it has been around 4% per year (cf. Order No. 291/2003, of 8 April, for the legal rate, although it may be adjusted annually).
• Voluntary regularisation: One of the most important mitigating factors in the sanctioning framework is the possibility of voluntary regularisation. If the taxpayer, on their own initiative, submits the overdue return and/or pays the due tax before any notification or inspection action by the AT, the applicable fines are substantially reduced. Article 32 of the RGIT provides for a significant reduction in fines in these cases, encouraging taxpayers to correct their errors. For example, the fine for late submission can be reduced to nominal amounts (e.g., €25 or €50) if regularisation is spontaneous and occurs in a timely manner.

In summary, prevention is the best strategy. Strict control of deadlines and correct preparation of tax returns are essential to avoid these penalties that can compromise the company's financial health.

Frequently Asked Questions about VAT Deadlines

What is the deadline for submitting the periodic VAT return in 2026?

The return must be submitted by the 20th day of the 2nd month following the tax period (month or quarter). Payment of the calculated tax must be made by the 25th day of the same month. For example, VAT for the 1st quarter of 2026 is submitted by 22 May and paid by 25 May 2026 (considering the adjustment of deadlines for public holidays/weekends).

From what turnover does VAT become monthly?

The VAT tax regime is monthly for taxpayers with a turnover equal to or exceeding €650,000 in the previous calendar year. Below this amount, the regime is quarterly, but the taxpayer can opt for the monthly regime by communicating this option to the AT.

Do I have to submit the return if I had no invoicing during the period?

Yes, the obligation to submit the Periodic VAT Return remains even if there were no operations (sales or purchases) during the period. In these cases, the return is submitted as "nil". Only taxpayers covered by the exemption regime under Article 53 of the CIVA are exempt from submitting the periodic return.

What is the fine for submitting the return late?

The fine for late submission of the periodic return varies between €150 and €3,750, as per Article 116 of the RGIT, with higher values for legal entities. If there is outstanding tax, a fine between 15% and 50% of the VAT due (for negligence) and late payment interest are added. However, voluntary regularisation before any action by the AT significantly reduces these penalties.

What is the recapitulative statement and when is it submitted?

The Recapitulative Statement (Model 32) is a document that reports intra-Community operations of goods and services (supplies, acquisitions, and services) between taxpayers in the European Union. It must be submitted by the 20th day of the month following that in which the operations occurred, or quarterly if the volume of operations is small. Its purpose is to feed the VIES system for controlling cross-border operations.

What are the August tax holidays for VAT purposes?

The August tax holidays refer to the rule that extends the deadlines for fulfilling tax obligations that would end in August to the first working day of September. In the case of VAT, the Periodic Return for June (monthly regime) or the 2nd quarter (quarterly regime), whose submission and payment deadline would fall in August, shifts to September without the application of fines or interest.

Conclusion and Practical Recommendations

VAT management in Portugal, particularly concerning the Periodic Return, is an ongoing responsibility that requires attention, rigour, and knowledge of current legislation. The changes introduced by Decree-Law No. 49/2025, which unified the submission and payment deadlines to the 20th and 25th respectively, aim to simplify the process but do not eliminate the need for meticulous tax planning.

To ensure tax compliance and avoid the heavy penalties associated with non-compliance, we offer the following practical recommendations:

1. Stay Updated: Tax legislation is dynamic. Regularly consult the Tax Portal and notices from the Tax Authority to stay abreast of any changes in deadlines or completion rules.
2. Organise Documentation: Good organisation of invoicing documents (issued and received) is the basis for accurate VAT calculation. Digitize and categorise invoices systematically.
3. Use Management Software: Use invoicing and accounting software certified by the AT. These tools automate VAT calculation, facilitate SAF-T generation, and Periodic Return submission, minimising errors.
4. Strictly Control Deadlines: Create a detailed tax calendar, with alerts for VAT submission and payment deadlines, including exceptions for tax holidays and public holidays.
5. Validate Data: Before submitting the return, compare the calculated values with e-Fatura and SAF-T data. Detecting and correcting discrepancies internally is always preferable to being notified by the AT.
6. Consider Professional Accounting: The complexity of the Portuguese tax system justifies, in most cases, resorting to a Certified Accountant. This professional not only ensures the correct application of the law and compliance with deadlines but can also advise on tax optimisation and more advantageous regimes for your activity.

The Periodic VAT Return is not just an obligation; it is also a management tool. Correct and timely submission reflects responsible financial management and contributes to the solidity and credibility of your company.

Do you want your VAT submitted on time, every period, without surprises? HVR Business Consulting offers a complete accounting service, ensuring your tax peace of mind. Contact HVR Business Consulting today to find out how we can help your company stay compliant. Hugo Ribeiro, Certified Accountant OCC nº 64356, with an office in Parque das Nações, Lisbon. Packages available from €150/month.

Sources and Legal References

• Value Added Tax Code (CIVA): Articles 2, 6, 14, 22, 27, 36, 41, 53.
• Decree-Law No. 49/2025: Wording of the CIVA in force from 1 July 2025.
• VAT Regime for Intra-Community Transactions (RITI): Article 14.
• General Regime of Tax Infractions (RGIT): Articles 32, 114, 116, 117.
• Tax Procedure and Process Code (CPPT): Article 57-A.
• Civil Code: Article 279 (subsidiarily applicable to deadlines).
• Order No. 291/2003, of 8 April: Sets the default rate of late payment interest.
• Tax Portal: Official information and tax calendars from the Tax and Customs Authority.