If you hold a Portuguese NIF and live outside the EU and EEA, your fiscal representative is the person or firm at whose Portuguese address the Tax Authority sends your official letters. People ask how to change that representative when a renewal comes up, when a provider stops responding or when their situation changes. This guide sets out what the Tax Authority itself publishes about replacing a representative. It is general information, not legal advice.
Can you change your fiscal representative in Portugal?
Yes. The Portuguese Tax Authority (Autoridade Tributária e Aduaneira, AT) handles a replacement through the same channels as a first appointment. Its page on tax representation asks you to file the appointment or the replacement request (nomeação ou pedido de substituição) on the Portal das Finanças, through e-balcão or at a tax office. The appointment is only final once the new representative accepts it. Source: Portal das Finanças, Representação (in Portuguese).
How does a replacement work, step by step?
Following the Tax Authority’s own instructions, there are four steps. Menu names change from time to time, so check the official page before you start.
- Agree with the new representative. They must be a person or a company with a tax address in Portugal, and they have to accept the role.
- File the request. Online, log in to the Portal das Finanças and go to Dados Cadastrais > Representante > Entregar Nomeação, choosing IRS (or IVA e IRS if you carry out an activity in Portugal). The alternatives are e-balcão (Registo de Contribuintes > Identificação > Representação Fiscal) or a Serviço de Finanças or Loja do Cidadão, by appointment.
- Attach the documents. If you file it, a declaration accepting the representation, signed by the new representative. If the representative files it, a power of attorney from you for that purpose; the signature does not need to be certified when the power of attorney is issued to a lawyer or solicitor identified as such.
- The new representative accepts. They confirm the appointment on the Portal das Finanças (Confirmar Nomeação), or both of you attend the tax office together.
Filing through the portal needs your own Portal das Finanças login (NIF and password, or Chave Móvel Digital). If you have not received your password yet, see how to log in with your NIF. The AT’s step-by-step page is in English: Appoint a tax representative.
Who can be your new fiscal representative?
A natural person or a company with a domicile (address or registered office) in Portugal. According to the AT’s leaflet on NIFs for non-resident foreign citizens, a foreign citizen can also be appointed if they hold a valid residence permit on the date they accept the role and are registered as a resident in the AT database. If you carry out a self-employed activity in Portugal that is subject to VAT, the representative must also be a VAT taxable person with a tax domicile in Portugal. Source: AT leaflet, Tax identification number to foreign citizens – non-residents.
What does a fiscal representative do, and what do they not do?
According to the AT, the representative receives the correspondence the AT sends you, complies with ancillary tax obligations (including filing income tax returns) and exercises your rights before the AT, such as complaints and appeals. As a rule they are not responsible for paying your taxes; the exception is VAT when the non-resident carries out a self-employed activity subject to VAT. For the everyday picture, see Fiscal Representative in Portugal: Who Needs One.
Where do your letters go after the change?
To the new representative’s address. The AT states that a non-resident who has appointed a representative has the representative’s address as tax address, so letters, and a Portal das Finanças access password if one is requested, are posted there once the replacement is registered. It helps to ask the current representative whether anything is still pending before the change takes effect.
Can you simply end the representation without a replacement?
Only if you are not required to have one. The AT says the obligation applies if you live outside the EU, Norway, Iceland and Liechtenstein and establish a legal tax relationship in Portugal, for example by owning real estate or a vehicle registered there, signing an employment contract to work there or carrying out a self-employed activity there. You then have 15 days to appoint a representative or to join one of the electronic notification channels (the notifications system on the Portal das Finanças, or the ViaCTT electronic mailbox). Joining a channel is not an alternative if you are self-employed in Portugal and subject to VAT. For residents of the EU, Norway, Iceland and Liechtenstein, appointing a representative is optional.
The AT’s page lists the law on the representative’s renunciation (article 130-A of the IRS Code) but does not set out a step-by-step cancellation procedure, so ask the AT through e-balcão or a tax office before ending a representation that is mandatory in your case. The AT’s leaflet adds that failing to appoint a representative when it is mandatory is punishable by a fine of €75 to €7,500.
What if you move to Portugal?
That is a different procedure from replacing a representative. The AT’s leaflet on the tax address of foreign citizens says that once you meet the conditions to be treated as a tax resident, you must communicate your residence in Portugal and update your data within 60 days. The conditions are the AT’s, so check the leaflet and ask the AT or a qualified tax adviser about your own case. Source: AT leaflet, Morada fiscal dos cidadãos estrangeiros (in Portuguese).
What if your representative is NIF Express?
With NIF Express, the first year of fiscal representation is included in the price (€49.99 adult, €74.99 minor). After that it renews every twelve months at the same amount as the period that has just ended, and we email you at least 30 days before each renewal charge so that you can stop it before it is charged. If you want to talk through your options before a renewal date, write to [email protected] (Monday to Friday, 10:00–17:00 Lisbon time). NIF Express is a private consultancy, not a Tax Authority service. To start a new application, see the NIF online service.
Frequently asked questions
Can I change my fiscal representative in Portugal?
Yes. The Tax Authority handles the replacement as a new appointment, filed on the Portal das Finanças, through e-balcão or at a tax office. The new representative has to accept the role, and the appointment is only final once they do.
How do I remove my fiscal representative?
It depends on whether you are required to have one. The Tax Authority’s page lists the law on renunciation (article 130-A of the IRS Code) but does not describe a step-by-step cancellation, so ask the AT through e-balcão or a tax office. Where a representative is mandatory, a fine of €75 to €7,500 applies to not having one.
Who can be my fiscal representative?
A person or a company with a tax address in Portugal. A foreign citizen needs a valid residence permit on the date of acceptance and must be registered as a resident. For a self-employed activity subject to VAT, the representative must be a VAT taxable person.
Where do my letters go after I change representative?
To the new representative’s address. The Tax Authority states that a non-resident with a representative has the representative’s address as tax address.
Do I need a fiscal representative if I live in the EU?
No. For residents of the EU, Norway, Iceland and Liechtenstein, appointing a representative or joining an electronic notification channel is optional.
Does the new representative have to accept?
Yes. A declaration of acceptance signed by the representative is attached when you file the request, or the representative confirms the appointment on the Portal das Finanças. The appointment is only finalised once they accept.
Is NIF Express a Tax Authority service?
No. NIF Express is a private consultancy and the online service of Blue Ocean Immigration. We prepare and file the application; the Portuguese Tax Authority issues the NIF.
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