Portugal’s new VAT grouping regime, effective from July 1 2026, introduces stricter eligibility criteria than other EU members, requiring a dominant entity to hold at least 75 % of share capital and 50 % of voting rights, and limiting participation to entities with a Portuguese head office that carry out deductible activities. The regime does not neutralise intra‑group supplies and may exclude financial and insurance groups with predominantly exempt activities.

The Court of Appeal ruled that public funds paid to further education institutions are third‑party consideration for the supply of education, placing them within the scope of VAT but exempt. HMRC accepts the judgment, will not pursue a further appeal, and maintains the current position pending consultation, meaning institutions can continue their existing VAT treatment until any future policy change applies prospectively.