Portugal's AT and the monthly mileage declaration for companies in 2026
Portugal's AT introduced a monthly reporting obligation in 2026 for reimbursements above €5,000. The guide.
The new obligation
Portugal's 2026 Budget Law (Lei 24/2025) added Art. 119 §5 of CIRS, creating a monthly declaration for companies reimbursing more than €5,000/month in mileage (€0.40/km) or its EV equivalent. AT published the model via Despacho 318-A/2026.
Goal: automate the cross-check between reimbursements and employee IRS, catching above-cap payments not declared as wages.
Who's obliged
Applies to companies (any IRC regime) reimbursing >€5,000/month, plus cooperatives, associations, foundations, and self-employed reimbursers above the threshold. Microbusinesses below €5,000 are out, as are companies entirely within the €0.40/km cap with digital logbook and documented approval.
What gets declared
Per employee, monthly: NIF, total km, rate, total paid, exempt vs taxable splits, vehicle plate, EV flag (for the differentiated rate planned in 2027). Submission via Portal das Finanças by the 10th of the following month.
€0.40/km treatment
Unchanged: at or below €0.40/km is IRS-exempt and outside social security; above the cap, the excess is taxable wages.
Annual 70,000 km cap
Decreto Regulamentar 4/2024 caps annual reimbursable km at 70,000 per employee; above that, the entire payment (not just the excess) becomes wages, on the presumption the vehicle has become a permanent work tool that should be company-provided.
Penalties
RGIT Art. 117: €150-€3,750 for a missing declaration, €25-€375 for late filing, 100%-200% of unpaid tax for material inaccuracy. Aggravated for repeat or willful conduct.
2027 EV-rate prep
The same Despacho signals a separate EV rate in 2027 (~€0.18-€0.22/km, aligned with UK AER). The declaration already includes the EV flag — companies with mixed fleets should begin separating fuel and EV counts immediately.