The Brazilian lawyer André Lima responds every week to a question from DN Brasil readers about immigration.
This week’s question came from a reader who asked the following: “Returning to Brazil, do I need to leave a tax representative in Portugal just because of the IRS declaration for the following year? Or can I join the digital notifications on the Finance Portal and deal with it myself?”
Lawyer André Lima responds
Returning to Brazil after living in Portugal is, for many people, completing a cycle. But, from a fiscal point of view, this “goodbye” is not just done with a packed suitcase and a purchased plane ticket. There is an essential step to avoid problems with the Tax Authority (AT): tax exit.
To recap: What is fiscal exit?
When someone stops living in Portugal on a regular basis and starts residing in another country, they are no longer considered a tax resident in Portugal. This has two main consequences:
• It is necessary to communicate the change of residence to the AT, updating the tax address to the new country;
• It is necessary to submit the IRS declaration for the following year, relating to income obtained while you were still resident in Portugal (and, in some cases, on income obtained later, if you still have a tax connection with the country).
In practice, this is done on the Finance Portal: 1. change the address to the destination country;
2. status is updated from resident to non-resident. The idea is simple: correctly close your tax chapter in Portugal, making it clear from what date you became a resident in another country.
This week’s question: do I need a tax representative when I return to Brazil?
The reader who wrote to us is returning permanently to Brazil, without leaving any assets or income in Portugal. The question was: “Returning to Brazil, do I need to leave a tax representative in Portugal just because of the IRS declaration for the following year? Or can I join the digital notifications on the Finance Portal and deal with it myself?”
Here are three concepts that intersect, but are not the same:
1. Tax exit;
2. Fiscal representative;
3. Electronic notifications.
Let’s go in parts.
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What is a tax representative?
The tax representative is a person, with an address in Portugal, appointed to the AT to:
• receive notifications, letters and official communications on behalf of the taxpayer;
• help fulfill obligations such as delivering statements, responding to notifications, clarifications, etc.
He does not become “responsible for your taxes”, but is the point of contact in Portugal. If a letter arrives from the AT or a requirement arises from the IRS, it is to this representative that the information goes.
If you’re a foreigner, this should look familiar:
• when you arrive in Portugal and are not yet a resident, you need a tax representative to request the NIF;
• when you leave Portugal and stop being a resident, but remain linked to the Portuguese tax system, the logic becomes very similar again.
Europe vs rest of the world: here’s the difference
And this is where the key point of your question comes in. Today, the rule makes an important distinction:
• If, upon leaving Portugal, you go to live in another country in the European Union (or the European Economic Area)
→ you can subscribe to electronic notifications (Finance Portal / ViaCTT / other supported channels) and, therefore, be exempt from appointing a tax representative, as long as you handle everything correctly through the digital channel.
• If, upon leaving Portugal, you are going to live outside of Europe — as is the case for those returning to Brazil
→ becomes a non-resident outside the EU/EEA and in this situation, It is mandatory to appoint a tax representative in Portugalalthough it also uses electronic notifications.
In other words, for a Brazilian returning to Brazil, digital notifications do not replace the role of a tax representative. They can even complement and make communication faster, but they do not remove the obligation to have a representative with an address in Portugal.
What about the IRS for the following year?
Even after returning to Brazil, you will have to:
• submit the IRS for the last year you were resident in Portugal;
• eventually, declare some income that still has a connection to Portugal (if applicable).
As long as this relationship with AT exists, and if you are outside Europe, the law requires that there be a tax representative in Portugal:
• to receive notifications about the IRS;
• to notify you of deadlines and requirements;
• and, often, to coordinate with the accountant or lawyer the submission of the declaration and the response to any correction.
So, in practice, what should the reader do when returning to Brazil?
Summarizing the step by step:
1. Make the tax exit
Update the address on the Finance Portal to the address in Brazil; o Check whether the situation is now listed as non-resident.
2. Establish a tax representative in Portugal
Choose someone with an address here (it could be a professional or a trusted person); o Formalize this representation with the AT.
3. Handle the final IRS calmly
Gather all documentation from the year of departure;
Submit the IRS the following year;
Monitor, through the representative, any communication from AT until everything is definitively resolved.
You can, additionally, subscribe to electronic notifications on the Finance Portal — which makes it much easier to consult the processes — but this, in your case (return to Brazil), does not exempt you from the tax representative.
Arrival and departure: the same care in opposite directions
When a foreigner arrives in Portugal, they often only obtain the NIF thanks to a tax representative, because they are not yet a resident.
When you decide to leave, especially outside Europe, the logic closes the cycle: in the same way that you needed a representative to enter the system, you need a representative to exit it safely.
It is this representative who will ensure that no letter from AT is lost, that the final IRS is handled correctly and that your tax story in Portugal ends without unpleasant surprises.
If you have your bags packed for Brazil and still have questions about how to organize your tax trip, it’s worth asking for guidance before boarding. A well-made adjustment now can avoid problems and fines in the future — and make your return to Brazil easier, at least from a tax point of view.