What is Fiscal representation in Portugal?
Fiscal representation in Portugal means assigning an individual or company to represent you in tax matters with the Portuguese Tax Authorities.
Once you designate a fiscal representative (also called a "tax representative"), they become responsible for receiving and forwarding any tax notices from the Portuguese Tax Authorities directly to you.
Understanding Physical Tax Mail and Why Electronic Notifications Alone Aren't Enough
A common and critical misunderstanding is that activating electronic notifications on the Portal das Finanças eliminates all physical mail from the tax authority. This is not the case.
As a matter of legal record, the Portuguese tax system requires certain high-importance documents to be formally issued and sent via physical post.
These notices may not appear in your online portal.
Documents commonly sent by physical mail include:
IMI (Annual Property Tax) payment bills
IUC (Annual Vehicle Tax) payment notices
IRS (Income Tax) assessments and compliance letters
Formal tax audit notifications, requests for clarification, and enforcement actions
Understanding this reality is essential for making an informed decision about your tax communication setup.
Who Needs a Fiscal Representative?
Whether you need a fiscal representative depends on your residency status and whether you have tax obligations in Portugal.
1. Non-EU/EEA Residents with Tax Obligations
If you live outside the EU/EEA and have tax obligations in Portugal (e.g., you own property or a vehicle, or earn income), you must have either a fiscal representative or active electronic notifications. The professionally recommended approach is to have both.
2. Non-EU/EEA Residents WITHOUT Tax Obligations
If you live outside the EU/EEA and have no tax obligations in Portugal, you can waive the fiscal representative requirement by activating electronic notifications.
3. EU/EEA Residents
If you are a resident of an EU/EEA country, fiscal representation is optional regardless of your tax obligations.
The 2022 Ruling Explained (Ofício Circulado N.º: 90057)
This ruling clarified the following:
EU/EEA residents do not need a fiscal representative.
Non-EU/EEA residents WITHOUT tax obligations can waive the fiscal representative requirement by enabling electronic notifications.
Non-EU/EEA residents WITH tax obligations must still have either a fiscal representative OR electronic notifications.
Why Keep Your Fiscal Representative Even with Electronic Notifications?
Even if you're not legally required to have a fiscal representative (for example, if you're an EU resident or have activated electronic notifications), maintaining one is highly recommended if you have tax obligations. Here are the key reasons:
Reliable Mail Delivery: When you have a fiscal representative, their Portuguese address becomes your official fiscal domicile. All critical physical mail is sent there, ensuring instant and reliable receipt. Without a representative, this mail is sent to your international address where it may be subject to postal delays or loss.
Peace of Mind: A fiscal representative acts as your secure legal mailbox in Portugal, eliminating the risk of missed deadlines and penalties. This is especially important for time-sensitive documents like IRS assessments or audit notifications.
Professional Standard: The dual system (fiscal representative + electronic notifications) is the standard of care used by lawyers and accountants to protect their clients.
How NovoMove's Fiscal Representation Works
When you obtain your NIF through NovoMove, you designate one of our affiliated lawyers as your fiscal representative.
This allows them to request a NIF on your behalf and receive your password to the Portal das Finanças. Beyond that, they will forward any communications addressed to you from the Portuguese Tax Authorities.
NovoMove includes 12 months of fiscal representation with your NIF service. After 12 months, you will be charged an annual fee to maintain your fiscal representation. You can see our pricing at novomove.com/pricing.
How to Cancel Your Fiscal Representation with NovoMove
Follow these instructions - How to cancel your fiscal representation with NovoMove.