Portugal's VAT-Group Regime Goes Live on 1 July, but the Tax Portal Isn't Ready to Enrol Companies

One of the more significant changes to Portuguese business taxation in years takes effect on 1 July: a VAT-group regime (Regime do Grupo de IVA) that lets companies in the same corporate group settle their value-added tax as a single, consolidated position rather than firm by firm. There is just one problem — the tax authority's own website is not ready to process the applications.

The regime was created by Law 62/2025 of 27 October and applies to VAT periods beginning on or after 1 July 2026. For the corporate groups it is aimed at, it is a genuine cash-flow reform; for the Tax and Customs Authority (Autoridade Tributária e Aduaneira, the AT), its launch has become an awkward illustration of policy outrunning plumbing.

What the regime actually does

Today, every company files and pays its own VAT. A group that contains one subsidiary perpetually in a refund position (because it invests heavily or exports) and another that consistently owes VAT cannot net the two against each other — the first waits months for the State to repay it while the second hands cash over on time. The result is working capital trapped on both sides of the same balance sheet.

The VAT-group regime breaks that logjam. It allows economic groups to consolidate their VAT balances, offsetting the amounts payable by some entities against the amounts recoverable by others and remitting (or reclaiming) a single net figure. For capital-intensive and export-heavy groups, that can free up meaningful sums and end the wait for refunds that has long been one of the most common complaints about doing business in Portugal.

Who qualifies

The regime is not open to any cluster of related companies. To form a VAT group, the entities must be bound by financial, economic and organisational ties. The controlling entity (entidade dominante) must hold, directly or indirectly, at least 75 percent of the capital of each controlled company, provided that stake also carries more than 50 percent of the voting rights. In practice this targets established corporate groups with a clear parent at the top, not loose webs of commonly owned firms.

The launch glitch

Here is where the rollout stumbles. Companies wishing to opt in were supposed to do so through the Portal das Finanças, the AT's online portal. But the authority has conceded that the IT work needed to adapt its start-of-activity and change-of-activity declarations will not be finished "in good time" for the 1 July start.

As a stopgap, groups that want to join from the outset must apply through the e-balcão, the portal's electronic help-desk channel. The request has to be submitted by the certified accountant (contabilista certificado) of the controlling entity, using the path "Registo Contribuinte > Atividade > Adesão aos Grupos de IVA." It is a manual workaround for a regime that was meant to be a click, and it puts the onus on accountants to get the paperwork exactly right while the automated route is built out behind the scenes.

What this means for expats

• Mostly a corporate-group story. The regime is built for groups with a dominant parent and 75-percent-plus holdings — not for a single freelancer or a one-company operation. If you run an independent activity on recibos verdes, nothing here changes for you.
• It can matter if you own a small group of companies. Foreign investors who hold a Portuguese holding company over one or more trading subsidiaries are exactly the profile this regime was designed for — and consolidating VAT could improve cash flow if one entity routinely sits in refund.
• Talk to your accountant before 1 July. Because opting in for the first period must go through the e-balcão and be filed by the controlling entity's certified accountant, this is not a do-it-yourself step. Anyone who wants the regime to apply from the start should be moving now.
• Another reminder that the portal can lag the law. This is the second AT system in a week to wobble at a deadline, after the 1 July changes to low-value parcel imports. When Portuguese tax rules change, the digital tooling does not always arrive on the same day.

For the groups that qualify, the VAT-group regime is a long-overdue alignment with a model already common across the European Union. The irony of its debut — a modernising reform that opens for business through a help-desk ticket rather than the portal it was promised on — is a fitting epigraph for the gap that so often separates Portuguese tax legislation from the systems meant to deliver it.