Do I have to declare my Rauva account in Annex J of my IRS Declaration?

Under Article 63-A, number 8 of the General Tax Law, "IRS taxpayers are obliged to mention in the corresponding tax return the existence and identification of deposit or securities accounts opened with a non-resident financial institution in Portuguese territory or with a branch located outside Portuguese territory of a resident financial institution, which they hold, benefit from or are authorised to operate."

This obligation is fulfilled by filling in box 11 of Annex J of the IRS Model 3 tax return and consists of merely identifying the accounts, having no impact on the tax assessment.

The legislation expressly refers to "deposit or securities accounts", so accounts of a different nature, namely payment accounts, are not covered by this obligation, as the Tax Authority explains in Circular Letter 20.211.

To this end, Rauva requested clarification from the Order of Certified Accountants, which clarified that it is not obligatory to declare the Rauva account in Annex J. The Rauva account, as well as being considered a payment account, is domiciled with its partner Swan, which is an e-money institution and does not operate on the market as a credit institution.

However, the taxpayer can declare the account if they wish to fulfill a formality.