Tax News | VAT – VAT Group Regime (RGIVA) – Exceptional Accession Procedure

1  july 2026

Background

Law No. 62/2025, of 27 October, introduced the VAT Group Regime (RGIVA), applicable as of 1 July 2026. This regime allows for the consolidation of VAT balances payable or recoverable by entities belonging to the same group, provided that such entities are linked through financial, economic, and organisational relationships.

Under this regime, VAT is determined on an aggregated basis at group level, with the domestic parent entity  responsible for submitting the VAT return on behalf of the group.

The option to apply the RGIVA must be exercised by the parent entity through the submission of a start-up or amendment of activity declaration, identifying all group entities and confirming compliance with the legal requirements. The regime is mandatory for a minimum period of three years.

As the IT developments required to enable the electronic option via the Portuguese Tax Authority (AT) Portal are not yet finalised, the Tax Authority has introduced an exceptional accession procedure, applicable until the online functionality becomes available.

Exceptional accession procedure

Until the electronic option becomes available on the AT Portal, accession to the RGIVA must be submitted by the parent entity through its Certified Accountant, via the e-balcão service, by filing a start-up or amendment of activity declaration under the “VAT Groups Accession” category.

For the purposes of the regime, the date of submission of the e-balcão request shall be considered the effective date of the option, provided that the request is properly supported with all required information.

Required documentation

The required documentation for the accession request, as well as the mandatory supporting elements (including the Excel file structure), should be consulted directly in Circular Letter No. 90087.

Rejection and validation of requests

Accession requests may be rejected or subject to requests for clarification where they are not properly completed.

The option to join the RGIVA is only considered valid once the request is fully complete, and the parent entity bears the burden of proof regarding the fulfilment of all legal requirements for application of the regime.

Entry into force

This Circular Letter produces immediate effect and applies to all requests submitted from 1 July 2026 onwards, remaining in force until the accession functionality becomes available on the AT Portal.