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Challenging a Tax Assessment in Portugal: Routes and Deadlines

Challenging a tax assessment in Portugal can proceed by four routes, and CPPT Article 102 generally allows three months for a judicial impugnation. Notification and the end of voluntary payment start the main periods, so those dates decide which challenges remain open.

Vineyard terraces above the Douro river near Pinhão

Common questions

How long is the deadline for a judicial impugnation?
CPPT Article 102 generally gives three months, counted from the event connected with the tax act, such as the end of voluntary payment or notification. The specific trigger and the competent tax court depend on the tax act.
What is the deadline for a reclamação graciosa?
CPPT Article 70 generally gives 120 days from the Article 102 events, subject to special rules. The complaint may be filed with the local tax service for the domicile, property or assessment and may be electronic.
How long is the deadline for a hierarchical appeal?
A hierarchical appeal against total or partial refusal of a complaint is lodged within 30 days of notification under CPPT Article 66(2), before the author of the act.
What hearing period applies before a tax decision?
LGT Article 60 gives a 15-day hearing period, which the tax authority may extend to a maximum of 25 days according to complexity. The response addresses the facts and the law of the draft decision.
How long can the tax authority assess?
LGT Article 45 generally gives the authority four years to validly notify a tax assessment, subject to the tax and statutory exceptions. The procedural history must be checked before a date is calculated.
When does a tax debt prescribe?
Tax debts generally prescribe after eight years under LGT Article 48, with counting rules and interruption or suspension causes that depend on the tax and enforcement history.
Is there a threshold or fixed fee for tax arbitration?
RJAT Articles 2 and 3 do not state one general monetary threshold or universal filing fee. Article 10(1)(a) gives a 90-day period for the relevant arbitration request, while the applicable CAAD cost schedule must be confirmed.
Who can represent a taxpayer in a tax dispute?
Reserved legal acts, including court representation, are carried out by a lawyer registered with the Ordem dos Advogados or by a solicitador. CPPT Article 5(2) limits tax-mandate work where legal questions are raised. The representative route depends on the proceeding and the issues.
What interest and payment date apply while a dispute is pending?
LGT Article 44 applies mora interest when tax is not paid by the legal deadline, with a doubling rule for the specified post-judgment period. The payment date is the one on the assessment or enforcement document unless a special rule applies.