3813497 - How does Concur comply with the Portuguese Tax Authority's regulatory framework of DL 28/2019 with regard to Digital Tax Compliance?

Do you have any knowledge of this topic for Portugal?

“The topics discussed between us and our tax team:
As discussed:
• Filing deadline - 10 years
• Rule: taxpayers based in Portugal who receive paper invoices must keep these documents in a facility/establishment within national territory.
• Exception: paper documents can be scanned and archived electronically, provided that, notably:

With the necessary technical precision, scanning and electronic archiving are performed to obtain and reproduce perfect, legible, and intelligible images of the original documents, ensuring their consultation and reproduction on paper or electronic media without any loss of information.
• The archive creation ensures:
o Executing controls that ensure the integrity, accuracy, and reliability of the archiving process.
The implementation of security features in order to prevent unauthorized creations and to detect any alteration, destruction, or deterioration of the archived records.

After ensuring the mentioned controls are in place, it is possible to destroy the original paper documents issued or received. For invoices for the acquisition of goods or services, it is necessary to exercise the right to deduction and register the invoice.

Third parties (e.g., Concur) can be responsible for archiving, and all records or groups of records must have checksums. An image or group of images is verified as being intact with this code (e.g., hash). By recalculating and validating it, we can assess whether or not modifications have occurred.


An archiving plan is required.

Maintain regular checks of the legibility of the digitally archived data, and back up the electronic media. Forarchives to be secure, originals and backups must be kept in separate locations under suitable preservation conditions.

We should start by verifying with Concur that the tool we are using conforms to the Portuguese Tax Authority's regulatory framework of DL 28/2019 and whether they have confirmation from them (e.g., by responding to a binding information request).

KBA , CON-EXP-ADM-TAX , Tax Administration , Problem