On October 27, Law No. 62/2025 was published, an optional regime consisting of the consolidation of VAT balances payable or recoverable between companies in the same group, linked by financial, economic, and organizational ties.
Criteria for companies to opt for the regime:
- The member companies must be closely linked to each other by financial, economic, and organizational ties, must pursue similar, complementary, or interdependent economic objectives, and must have a common management structure or be subject to the same business strategy;
- The controlling entity must hold a direct or indirect stake of at least 75% of the capital, provided that such stake gives it more than 50% of the votes;
- The registered office or permanent establishment of all member companies must be in Portugal;
- All member companies must be subject to the normal VAT regime on a monthly basis and carry out, in whole or in part, transactions that confer the right to deduction;
- Companies belonging to a VAT group cannot belong to another VAT group.
Once the criteria have been met, it is up to the controlling entity to opt for the application of this regime, which takes effect from the tax period corresponding to its submission, and it is mandatory to remain in this regime for a period of at least three years.
Even so, the member entities still have to submit their own returns and calculate the VAT payable or creditable. In turn, the controlling entity submits a single group return, consolidating the balances of all member entities and making the payment or using the credit.
What is the impact on companies participating in the scheme?
This new scheme offers companies greater efficiency in tax management through the automatic offsetting of VAT balances, thereby reducing the need to request individual refunds and simplifying internal procedures.
The scheme came into force the day after its publication (October 28) but only takes effect for VAT periods beginning on or after July 1, 2026.
