Tax Guide 2025 – Tax Penalties

Failure to file the statement of commencement, changes or cease of activity (Corporate Income Tax, VAT)

600 to 7,500

Failure or delay in filing statements related with the special regime of group taxation (“RETGS – Regime Especial de Tributação de Grupos de Sociedades”)

1.000 to 22.500

Failure or delay in the filing tax returns which aim at assessing the taxable amount (e.g. CIT and VAT tax returns)

300 to 3,750

Failure, delay, omissions and inaccuracies in the filling of the statement related to the transfer of funds to countries, territories or regions with a more favorable tax regime

6,000 to 165,000

Failure or delay in filling or omissions and inaccuracies in the statement concerning the payment flows by credit or debit cards or other means of electronic payments

6,000 to 165,000

Failure or delay in the payment of the tax due (e.g. VAT, withholding taxes, payments on account, additional payments on account, special payment on account, stamp tax, property transfer tax, etc)  ^{(2) (3)}

30% to 100% of the tax due

Lack of presentation of the transfer pricing documentation within the deadline established by the tax authorities

1,000 to 10,000, plus 5% per each day of delay

Failure to file, within the deadline established by the tax authorities, of the financial and tax reporting statement per country (Country by Country Report) in respect of the entities part of a multinational group, as well as the communication identifying the declaring entity 

1,000 to 10,000, plus 5% per each day of delay

Late issuance (after the legal deadline) of certificates of residence (EU Directives and Conventions for the elimination of Double Taxation)

750 to 3,750

Omissions or inaccuracies in documents that are relevant for tax purposes in case tax is due (e.g. filing of replacement returns) ⁽²⁾

750 to 22,500

Omissions or inaccuracies in documents that are relevant for tax purposes in case no tax is due (e.g. filing of replacement returns)

187.5 to 5,625

Omissions or inaccuracies in respect of acts, facts or documents which are relevant for the analysis of urgent binding ruling requests

750 to 22,500

Omissions or inaccuracies regarding acts, facts or documents which are relevant for the analysis of non-urgent binding ruling requests

187.5 to 5,625

Inexistence of software to extract files (Standard Audit File for tax purposes – Portuguese version / SAF-T PT)

450 to 22,500

Preparation of a data export standard file without observing the data model structure established in the law

500 to 5,000

Failure to use certified invoicing software

3,000 to 18,750

Failure to prepare accounts in accordance with the Portuguese accounting standards (“SNC – Sistema de Normalização Contabilística”)

1,000 to 10,000

Delay in the preparation of accounting or books records, or in the preparation of other accounting data or records

500 to 5,000

Failure or delay in the issuance invoices or receipts

300 to 3,750

Failure to request the issuance of invoices or receipts

150 to 2,000

Failure to keep invoices and receipts during the legal archive period invoices and receipts

150 to 2,000

Failure or delay in communicating data of invoices or of inventories

400 to 10,000

Failure to hold a bank account when mandatory

540 to 27,000

Failure to perform operations through a bank account

360 to 4,500

Payments made in cash above the legal limits

360 to 4.500

Lack of appointment of a tax representative appointment as well as appointment that omits the explicit acceptance of the tax representative

150 to 7,500

Lack of identification of the manager of assets and rights by the tax representative of a non-resident

150 to 3,750