Transport documents in Portugal: the goods-in-circulation rules (DL 147/2003)

All goods in circulation in Portuguese territory that are the object of transactions by VAT taxable persons must travel with a transport document (DL 147/2003, annex, art. 1). “Goods in circulation” means goods outside their places of production, storage or display. A transport document can be an invoice, a guia de remessa, a nota de devolução (return note), a guia de transporte or an equivalent document (art. 2(1)(b)). The AT states that there is no difference in content between a guia de remessa and a guia de transporte; businesses use one or the other according to commercial practice — see guia de transporte vs guia de remessa.

Exclusions relevant to construction include the sender’s own fixed assets (for example, its own equipment moving between obras), returnable containers and packaging such as returnable pallets, and change of premises with prior notice (art. 3(1)). Retail sales to final consumers are excluded, except construction materials carried in a goods vehicle (art. 3(2)(d)).

Article 4(2) and (4) set the minimum content:

• Name, address and NIF (tax number) of the sender.
• Name and address of the recipient or buyer, and the recipient’s NIF when it is a taxable person.
• Commercial description of the goods, with quantities.
• Places of loading and unloading, identified as such, and the date and time the transport starts.
• The document’s ATCUD unique code (required on transport documents under DL 28/2019 and communicated with the document).

The recipient has no communication obligation (Portal das Finanças FAQ). An invoice issued electronically that serves as the transport document is exempt from prior communication, because the invoice is reported through e-fatura (art. 5(11)).

1. 01The sender issues the document electronically, through AT-certified software, directly on the Portal das Finanças, or on pre-printed paper from an authorised printer (art. 5(1)).
2. 02Before the transport starts, the sender communicates the document’s elements, including the ATCUD, to the AT — by webservice, file (SAF-T), or on the Portal (art. 5(5)–(6)).
3. 03The AT returns an identification code proving prior communication (art. 5(7)). The code is only assigned if the communication happens before the start time of the transport.
4. 04For pre-printed paper documents or a proven IT failure, the sender may communicate by phone and must then enter the data on the Portal by the 5th working day (art. 5(6)).

Communication to the AT is not mandatory for taxable persons whose turnover in the previous tax period was €100,000 or less (art. 5(10)). They must still issue the transport document. A small local supplier may therefore hand over a guia with no AT code; that alone is not a defect.

Where the recipient is not known at departure — typical of goods sent to be incorporated in the sender’s own works — the sender issues a global document and, at each delivery, a document in duplicate; goods leaving to be incorporated in the sender’s own services are recorded in a separate document, “namely a folha de obra” (site work sheet), referring to the global document (art. 4(6)–(7)). These are communicated by the 5th working day after the transport (art. 4(11)).

Article 6(6) requires the sender’s and recipient’s copies to be kept until the end of the fourth year after issue, without prejudice to CIVA art. 52. Where the guia supports an accounting entry — for example, filed with the purchase invoice — the general rule for accounting support documents is 10 years (CIVA art. 52; DL 28/2019 art. 19). A prudent practice is to keep guias for 10 years; confirm your policy with a contabilista certificado. Decreto-Lei 35/2025 did not change these rules: in this regime it only amended art. 4(10), on small retailers and the VAT exemption scheme.

Audiree reads each guia from a photo taken on site — articles, quantities, units — and checks it against the contract and the invoice with AI, so the office does not re-type or re-check what the obra already signed. It uses the document number and ATCUD with the supplier to catch duplicates; it does not validate ATCUDs or transport codes with the AT, and it is not a certified tax archive. More in guia de remessa explained.