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New requirement in Portugal could impact SAP system configuration

New requirement in Portugal could impact SAP system configuration

4 February 2013

By Robbert Hoogeveen and Richard Cornelisse of the KEY Group

This blog is about making you aware of a new requirement in Portugal that could impact your SAP system configuration.

We believe that it is a very complicated change that will require a lot of IT resources.

You could ignore this blog in case your company does not have a legal entity that is subject to Portuguese Corporate tax. In that case the described new requirement is not applicable to you.


The requirement in Portugal for the submission of the so-called SAF-T PT reports has been changed recently.

The submission of SAFT-PT files to the Tax Authorities was not mandatory and the SAFT-PT should be available when requested.

At the end of August 2012 was published the Law-Decree nº 198/212 that predicts the submission of all the invoicing details in a monthly basis as a new monthly tax compliance obligation for the company that should occur until the day 8 of the following month (the first one is on February 8th).

This will be extended most likely to day 25 of the following month.

Only in the week of November 12th Tax Authorities clarified this Law-Decree giving the companies guidance for being compliance with the new legislation.

There is a standard SAP transaction to create the so called SAFT-PT files but based on our analysis, see attached document SAFT PT practical solutions for implementation, we believe that it will be very challenging to implement a full working solution in SAP before January 2013.

Especially because most SAP environment will be in the “freeze” status due to year end closure.

To be compliant for tax in Portugal it are challenging times. Besides the SAFT-PT requirement there is also a requirement to implement a digital signature for all sales invoices in Portugal.

We are curious how your company evaluates the risks of not meeting the Portuguese data request and whether it is likely that this provides the authorities a reason for a tax audit.

Our gut feeling says that this is of a higher risk level nowadays as countries as Portugal are using all kinds of methods possible to increase tax revenues in order to combat their deficit, but also depends on the local relation with the tax authorities of course.




Take aways 

We combine technical knowledge with industry understanding and knowhow of technologically advanced tools and methodologies available in the market or developed by ourselves.

  • Focus on tax processes that could be improved
    • Manual process: same data requests are made by different stakeholders
  • As Is assessment
  • Anticipate future changes and the data needed
    • What are tax trends?
    • What is happening locally and what should be considered across jurisdictions where you operate?
    • Anticipate new stakeholders and their data needs or requests (internal and external)
  • Define scope and actions for short, mid and long term
  • Write business case for change
  • Realize sponsorship for implementation
  • What tax data is requested and by whom?
  • What tax process can be improved and what can be automated?
    • CIT, VAT, tax data warehouse
  • What is the Return on Investment?
    • Hard saving: process improvement
    • Meeting (new) tax requirement
  • What systems are in use: SAP, Oracle, etc
    • By which entities?
  • How many end-use computing tools (e.g. excel spreadsheet) do we have?
  • How do we avoid an ad-hoc solution?
    • Understand the bigger picture
    • Real problem and not the symptom

Technology-related tax risk: understand and address the potential harms and benefits of (new) technology.

Ascertaining proper IT support for ensuring efficient, timely and reliable reporting.

VAT should be considered in every aspect of the process, from concept through completion and beyond. Managing by design — looking at any process or transaction from end to end and factoring in all the requirements and controls essential to designing and optimizing a compliant VAT process.

We speak the language of the business and IT and no translation is needed.