We hereby inform the business community and other interested parties that Law No. 10/2025 of 29 December has been approved, introducing amendments to the Value Added Tax Code, approved by Law No. 32/2007 of 31 December, and subsequently amended by Law No. 3/2012, of 23 January, and amended and republished by Law No. 13/2016 of 30 December,  by Law No. 22/2022 of 28 December and by Law No. 3/2025 of 21 May (‘‘VAT Code’’).

Accordingly, Articles 3, 6, 12, 18, 19, 21, 23, 25, 26, 27, 31, 32, 33 and 34 have been amended and, Articles 25-A and 53 have been added.

Among the changes introduced, the following key changes are highlighted:

• Digital goods are now subject to VAT and fall into the category of tangible assets;
• Digital goods and services supplied by a provider that has no registered office, permanent establishment, or domicile in the country are also subject to VAT[1]. In such cases, the corresponding VAT obligations shall be fulfilled by the purchaser established in the national territory, in accordance with the applicable regulations;
• It has now become mandatory to submit a monthly return, together with a summary of the withholdings made, for transactions involving the supply of goods and digital services by non-residents, when the purchaser is a taxable person located in the country;
• There is no right to deduct VAT for the transfer of goods and services subject to a reduced rate of 5%;
• It was clarified that only taxpayers registered for VAT are entitled to deduct VAT in relation to the tax shown on invoices or equivalent documents, and import dispatch tickets issued in legal form, in their possession;
• Entities with more than one establishment must, in the periodic declaration/VAT return, indicate the sales by establishment and other transactions carried out in such establishments, under the terms to be regulated;
• The deadline for granting of VAT Refunds by the Tax Administration , when due, has been extended from the previous 30 days to 150 days;
• A statute of limitations of 10 years, counted from the date the right to deduction arises, has been introduced for exercising the right to a VAT refund;

The deadlines for the submission of monthly returns have been changed, in the following terms:

- By the 15^th day of the following month, in the case of declarations with credits or without operations;

- Until the last day of the following month, for declarations that involved payment of tax; and

- Until the 10^th day of the following month, for transactions related to the transfer of goods and digital services carried out by non-residents, when the acquirer is a taxable person.

• Taxpayers who carry out occasional taxable transactions, even if they do not engage in regular activity, provided that the conditions for taxable incidence under IRPS and IRPC are met, must submit the corresponding declaration to the competent authority by the end of the month following the completion of the transaction;
• The special VAT regimes, namely the exemption regime and the simplified taxation regime, were repealed, and taxpayers initially registered in these regimes are required to comply with the VAT obligations applicable to organized accounting regime.

The above-mentioned amendments are in force since 01 January 2026.

[1] Except where the purchaser is established or domiciled abroad.