A notice arrived from the tax authority: what to do, and within how many days

By Hugo Ribeiro, Certified Accountant OCC · HVR Business Consulting · 8 August 2026

A notice from the Portuguese tax authority placed in the secure area of the tax portal is deemed served on the 5th day after the availability record, even if nobody opens it (art. 38-A(4) of the Code of Procedure and Tax Process, CPPT); on ViaCTT, on the 15th day (art. 39(10) CPPT, as amended by Law 119/2019). The first step is to tell a notice from a summons: a summons means tax enforcement proceedings are already running against the company and opens 30 days to file opposition to enforcement (art. 203(1) CPPT). The second is to check whether the notice contains the five mandatory elements of art. 36(2) CPPT: the decision, its grounds, the available remedies, the deadline to react, and the identity of whoever issued the act. If the grounds or the remedies are missing, the company has 30 days to demand what was left out, and the deadline to complain or challenge only starts running from that second notice (art. 37(1) and (2) CPPT).

Notice or summons? They are not the same thing

A notice is "the act by which a fact is brought to a person's knowledge or someone is called before a court"; a summons is the act "intended to inform the debtor that particular enforcement proceedings have been brought against them" (art. 35(1) and (2) CPPT). The distinction changes both the deadline and the remedy.

If the document speaks of opposition, attachment or the sum being enforced, it is a summons.

The clock is already running, even if nobody opened anything

Counting does not depend on the director having read the notice: the law presumes service on a fixed date, and the presumption can only be rebutted where later receipt is not attributable to the recipient (art. 39(2) and (11) CPPT).

That last line is almost never written down and it is the one that costs most: inside an inspection the 15-day ViaCTT rule does not apply, and anyone counting 15 loses ten days of their prior hearing.

Deadlines in the tax procedure and in judicial challenges run continuously, under art. 279 of the Civil Code (art. 20(1) CPPT): August counts. Deadlines for acts in judicial proceedings, of which opposition to tax enforcement is the most frequent, are counted under the Code of Civil Procedure (art. 20(2) CPPT) and are suspended during court holidays, as the Supreme Administrative Court has repeatedly held.

The five elements a tax authority notice must contain

Tax acts affecting taxpayers' rights and legitimate interests "only take effect in relation to them once they have been validly notified" (art. 36(1) CPPT); the effectiveness of the decision depends on the notice (art. 77(6) of the General Tax Law, LGT).

A notice always contains the decision, its grounds, the available remedies, the deadline to react and the identity of the body that issued the act (art. 36(2) CPPT).

For that last element the sanction is the strongest in the Code: the act of notification "shall be null where the author of the act is not identified" and, where they acted under delegation, of the capacity in which they decided, the direction and the date (art. 39(12) CPPT). Nullity of the notice, not of the act notified: the consequence is that the act produces no effects against the company (art. 36(1) CPPT; art. 77(6) LGT) and no deadline to react begins to run.

The tax authority may nonetheless send only a summary of the grounds, provided it expressly refers to the full reasoning in the secure area (art. 38(13) CPPT).

A notice without reasons: the consequence nobody writes down

A notice lacking the legally required statement of reasons is not effective: it does not fully produce its effects, because it does not allow the recipient to understand the scope of what was communicated. A complete absence of notice is an invalidity for breach of an essential formality, and can be invoked to annul the acts that followed it.

The remedy is set out in the Code and it is cheap. Within 30 days, or within the deadline for a complaint or judicial challenge if that is shorter, you may request notification of the omitted requirements, or a certificate containing them, free of any charge (art. 37(1) CPPT). The deadline to react is then counted from the delivery of that notice or certificate (art. 37(2) CPPT).

Deadlines to respond: prior hearing, administrative complaint and opposition

Three notes. The defence deadline for an administrative offence is now 30 days; a lot of material still in circulation says 10 or 15, which is the wording before Law 7/2021. Paying the fine within that deadline reduces it to the legal minimum and halves the costs (art. 75(1) RGIT); asking to pay the fine before the end of the prior hearing in an inspection reduces it to 50% of the legal minimum, provided the tax position is regularised (art. 30(1)(b) and (3) RGIT, as amended by Law 7/2021).

And a hierarchical appeal has devolutive effect only (art. 67(1) CPPT): it does not suspend the effects of the act. Silence from the tax authority for more than four months counts as a refusal (art. 57(1) and (5) LGT).

Where the tax authority serves a company

Companies are summoned or notified at the electronic mailbox or in the secure area of the tax portal, or in the person of a director or manager, at the registered office, at their residence or wherever they are found (art. 41(1) CPPT). Where the representative is not found, service is made on any employee at the place of administration capable of conveying the terms of the act (art. 41(2)); in liquidation or insolvency, on the liquidator (art. 41(3)).

The electronic mailbox is not optional: corporate income tax payers with their seat or effective management in Portugal, permanent establishments of non-residents, and residents on the normal VAT regime must hold one and report it to the tax authority within 30 days (art. 19(12) LGT). Anyone who does not report it is instead served in the secure area of the tax portal (art. 38-A(1)(a) CPPT): non-compliance does not stop the notices, it moves them to a channel nobody watches.

Any change of registered office or electronic mailbox must be reported within 15 days (art. 43(1) CPPT); failing that, non-receipt of notices cannot be raised against the tax authority (art. 43(2)).

A summons in tax enforcement: what to do in the 30 days

The summons communicates the deadlines for opposition and for payment in kind, and that payment in instalments may be requested up to the date the sale is scheduled (art. 189(1) CPPT). There is only an absence of summons where the recipient alleges and shows that they never became aware of the act for a reason not attributable to them (art. 190(6)).

Suspending the enforcement. It is suspended until the dispute is decided where there is an administrative complaint, a judicial challenge or a judicial appeal about the legality of the debt, provided a guarantee is given or the attachment covers the whole of the sum being enforced plus additions (art. 169(1) CPPT).

Smaller debts. Suspension for up to 120 days, counted from the end of the voluntary payment period, for debts below €5,000 (individuals) or €10,000 (companies), regardless of guarantee, ceasing 15 days after the administrative or judicial remedy is filed (art. 169(3) CPPT, as amended by Law 7/2021).

Reversal against the director. It is preceded by a hearing of the subsidiarily liable person and by a reasoned statement of the grounds and extent, to be included in the summons (art. 23(4) LGT). And the director is exempt from costs and from late payment interest charged in the proceedings if, once summoned, they pay within the opposition period (art. 23(5)).

Meanwhile the cost runs: the rate of late payment interest on debts to the State is 7.221% a year in 2026 (IGCP Notice 18/2026/2, Official Gazette 2nd series no. 1 of 2/1/2026, by reference from art. 44(3) LGT). Not to be confused with compensatory interest, at 4% a year, which forms part of the tax debt itself (art. 35(8) and (10) LGT, and Ordinance 291/2003).

Frequently asked questions

How long do I have to respond to a notice from the tax authority?

It depends what was notified. For the right to a hearing it is 15 days, extendable by the tax authority to 25 (art. 60(6) LGT); on a draft inspection report, between 15 and 25 days (art. 60(2) RCPITA). For an administrative complaint, 120 days (art. 70(1) CPPT); for a judicial challenge, three months (art. 102(1)). Where neither the law nor the tax authority sets a deadline, it is 10 days (art. 23(2) CPPT).

What is the difference between a notice and a summons?

A notice brings a fact or a decision to the knowledge of someone already connected to the procedure (art. 35(1) CPPT); a summons calls someone into tax enforcement proceedings for the first time (art. 35(2)). Once a summons is received the debt is in coercive collection and there are 30 days to file opposition, counted from personal service or, failing that, from the first attachment (art. 203(1) CPPT).

I received a notice with no statement of reasons. What can I do?

A notice lacking the legally required reasoning is not effective. Within 30 days, or within the complaint or challenge period if that is shorter, you may request notification of the omitted requirements or a certificate containing them, free of any charge (art. 37(1) CPPT). The deadline to react is then counted from delivery of that notice or certificate (art. 37(2)). Where the author of the act is not identified, the notice is null (art. 39(12) CPPT).

Does a ViaCTT notice count even if I never open it?

Yes. Notices to the electronic tax domicile are deemed served on the 15th day after the availability record, counting from the next working day (art. 39(10) CPPT). In the secure area of the tax portal the period is 5 days (art. 38-A(4)). Inside an inspection procedure, both channels count on the 5th day (art. 43(5) RCPITA).

Is my company required to have an electronic mailbox?

Yes, if it is a corporate income tax payer with its seat or effective management in Portugal, a permanent establishment of a non-resident entity, or a resident on the normal VAT regime. It must be reported to the tax authority within 30 days of starting activity or of entering the normal regime (art. 19(12) LGT). Without that report, the company is served in the secure area of the tax portal instead (art. 38-A(1)(a) CPPT).

Can my certified accountant be served instead of the company?

No. A certified accountant does not replace the taxpayer as the addressee of a notice, absent a mandate or a specific legal provision: it is addressed to the taxpayer or their legal representative. The company continues to be served at the electronic mailbox, in the secure area of the tax portal, or in the person of a director or manager (art. 41(1) CPPT).

Sources and legal references

• CPPT, Code of Procedure and Tax Process (Decree-Law 433/99 of 26 October, consolidated version in force): arts. 20, 23, 35 to 39, 41, 43, 66, 67, 70, 76, 102, 169, 189, 190 and 203.
• LGT, General Tax Law (Decree-Law 398/98 of 17 December, consolidated version in force): arts. 19, 23, 35, 44, 45, 57, 60 and 77.
• RCPITA, Complementary Regime for Tax and Customs Inspection Procedures (Decree-Law 413/98 of 31 December, so named by Law 75-A/2014): arts. 43 and 60.
• RGIT, General Regime for Tax Infringements (Law 15/2001, as amended by Law 7/2021, in force from 1/1/2022): arts. 30, 70, 75, 79 and 80.
• Ordinance 233/2019 of 25 July — electronic notices and summonses on the tax portal.
• IGCP Notice 18/2026/2, Official Gazette 2nd series no. 1 of 2/1/2026 — late payment interest, 7.221% in 2026; Ordinance 291/2003 — statutory interest, 4%.
• Order of Certified Accountants, "Practical Guide: Notification and Summons in the Tax Procedure and Process", April 2026.

Legal texts consulted in the consolidated versions published by the tax authority at info.portaldasfinancas.gov.pt and at diariodarepublica.pt, in August 2026. Informative article; it does not replace analysis of the specific case.