Modelo 3 and Anexo G: Filing After a Property Sale

Filing is where the whole selling year settles its account, and the Portuguese system’s defining feature is that 0% is withheld at the deed: no retention, no payment on account. The transaction completes, the proceeds move, and the tax relationship goes quiet until the following spring, when Modelo 3 opens on 1 April and every disposal of the prior year, taxable, exempt or loss-making, is declared by 30 June. The quiet period is where files are won and lost. Sellers who spend it assembling deeds, faturas and invoices meet the return as data entry; sellers who spend it assuming the deed settled everything meet an assessment built from the notarial feed with none of their deductions in it. The walkthrough below follows the form itself: who files, which annex, field by field, then the assessment, the divergência letter and the corrections regime.

Who files, and in which annex?

Filing obligation is tied to the disposal rather than the outcome: any sale of Portuguese property is declared in the following year’s Modelo 3, inside a window of 3 months from 1 April to 30 June, with Anexo G carrying taxable disposals and Anexo G1 the non-taxed cases, which in this market means chiefly property acquired before 1 January 1989.

Situation	Annex	Tax result
Standard sale, bought after 1989	G	Half the net gain at 14.5-48%
Property acquired before 1 Jan 1989	G1	Declared, not taxed
Sale at a loss	G	No tax; loss carries forward 5 years
Main-home sale with reinvestment	G, with the reinvestment declared	Relief on the reinvested share
2026-2029 sale reinvested into rental housing	G, with the regime claimed	Exemption under the housing package
Inherited property sold	G	Acquisition value = VPT at succession
Non-resident seller, any of the above	Same annexes, non-resident status marked	Resident basis since 2023

Annex choice does real work in mixed files, and mixed files are common in this market: a property held in stages, half inherited in 1985 and half purchased in 2005, splits across both annexes, each share carrying its own dates, values and coefficient years. Misplacing the pre-1989 share into G manufactures tax where none is due, roughly €12,000 of phantom liability on a €200,000 share at typical bands, while placing a taxable 2005 share into G1 understates the return and invites the divergência letter with penalties attached. The registry history on the certidão decides the split, not memory, and pulling it before filing costs €15 against either error. Sellers with any staged acquisition, inheritance quota or divorce transfer in the property’s past should treat the annex question as the first field of the return rather than the last.

Insider tip: order the certidão permanente online before the window opens. The registry history, not memory, decides any annex split, and the same document pre-answers the 2 commonest divergência triggers, share inconsistencies and questioned acquisition dates, for €15, against correction procedures that consume months.

Non-residents file identically in structure, marking status, and since 2023 the computation runs on the resident basis, with the practical difference that access and correspondence flow through whatever representation or portal setup the seller maintains, which is worth verifying weeks before the window rather than inside it.

What goes into the fields of Anexo G?

Field mechanics are simple and unforgiving: Anexo G takes dates, values, shares and deductions per property across 5 input groups, computes nothing visible, and hands the calculation to AT, so for foreign buyers turned sellers, a single input error propagates silently into an assessment arriving 1 to 3 months later with appeal windows already running.

The inputs, in the order the form wants them:

1. Identification of the property: the matrix article from the caderneta, parish codes, and your ownership share as a percentage.
2. Realisation: sale date and value, where value is the higher of deed price and VPT at sale, the same rule the mais-valias formula applies throughout.
3. Acquisition: date and value, the deed price for purchases, the stamp-duty VPT for inheritances and gifts, each share on its own row where histories differ.
4. Charges and works: one field carrying the sum of acquisition costs, the IMT, stamp duty and notarial fees paid at purchase, plus documented works from the last 12 years and the selling costs, commission with VAT, certificates, mediation.
5. Reinvestment declarations: intention or completion for main-home relief, and the claims under the 2026-2029 rental reinvestment regime where they apply.

The charges field is where money is left behind, because it is one number summarising a folder: sellers enter what they can prove, and what they can prove is whatever survived from the purchase and the works years. The selling cost stack is deductible line by line, and a €29,000 stack omitted from the field is roughly €5,000 of tax volunteered at a typical band.

Insider tip: reinvestment intention must be declared in the return for the year of sale even when the reinvestment itself happens later inside the window. The relief architecture runs on that declared intention; a seller who reinvests perfectly but never ticked the box litigates for what a checkbox would have granted.

What happens between filing and payment?

Assessment sequencing is fixed and calm when the file is clean: returns filed by 30 June are assessed with notes issuing normally by 31 July, payment falls due by 31 August, and the portal shows each stage, which in this market makes the 3 months after filing a monitoring task rather than a mystery.

The timeline with its decision points:

• Filing confirmation lands immediately; the submitted return and its annexes stay downloadable, and this copy is the reference for any later question.
• The assessment note states the computed gain, the tax and the payment reference. Read it against your own calculation before paying: agreement means the file closes, disagreement means the correction paths below.
• Payment by 31 August, through the reference, from any account. Nothing was withheld at deed, so the cash planning belongs to the seller, ideally provisioned from proceeds at completion rather than discovered in August.
• Instalments on application where the amount warrants it, up to 36 months with interest on the deferred balance, applied for inside the window to stay in the ordinary regime.
• Refunds flow the other way where withholdings or prior payments exceed the assessment, at the same administrative pace.

Worked case study: a seller completes in September 2026, nets €470,000, and provisions €26,000 of expected tax in a separate account the same week, based on the calculation run before listing. The following July the assessment lands at €25,400, within 3% of the estimate because the folder held every fatura the estimate assumed, and August’s payment is a transfer already funded. The entire tax phase of the sale consumed about 1 hour across 2 summers.

The identical sale unprovisioned meets the same €25,400 as an August liquidity problem 11 months after the money arrived, at exactly the moment the proceeds have found other purposes, and the instalment application that rescues it adds interest to a bill that planning would have made boring.

How do non-residents and joint owners actually file?

Access mechanics decide whether the filing is an evening’s work or a panic, and they differ by profile in this market: portal credentials with a Portuguese phone or the digital key for individuals, representation-mediated access for many non-EU sellers, and one return per owner where the property was held jointly, while password recovery by post can take 30 days.

Seller scenario: a Berlin owner selling an inherited Cascais quota files Anexo G1 for the pre-1989 half and Anexo G for the rest, uploads the certidão alongside the return, and the divergência letter never arrives, the file answered its questions before AT asked them.

• Joint owners file separately. A couple holding 50/50 files 2 returns, each carrying half the values in its own Anexo G, each assessed at its own rates; the split frequently lands both halves in lower bands than a single filer would face.
• Non-residents need working credentials before April. Password recovery to a foreign address takes weeks; testing the login in January costs 5 minutes and removes the single most common season-opening failure.
• Represented sellers should agree the filing engagement in writing, since representation alone forwards letters and files nothing.
• Marital regimes matter to the shares. Community-property couples selling a jointly acquired home split by the regime’s rules, not by whose name spoke at the deed.
• Heirs file for the estate’s disposals in the year of sale, each for their quota, with the succession VPT as the acquisition value.

Worked case study: a Chicago couple sells a jointly held Cascais flat in October. In January they test both portal logins, one fails, and recovery through the consulate route takes 5 weeks that would have consumed the filing window in May. Each files an Anexo G with 50% of the values the following spring; the split keeps each taxable half 2 bands below where a single return would have landed, saving roughly €3,100 against filing the whole gain on one head. The mechanics were trivial; the calendar discipline was the entire risk.

How do divergência letters work, and how do you answer one?

Divergência procedure is AT’s mismatch protocol: its data from the notarial feed, the registry, e-fatura and the banks disagrees with a field in your return, a letter states the point with a response window of typically 15 to 30 days, and the answer is documents uploaded through the portal rather than argument, in 5 patterns recurring across this market.

The common triggers and their answers:

Trigger	What AT sees	The answering document
Sale value mismatch	Deed feed differs from the return	The escritura itself
Works AT cannot verify	Deductions without matching e-fatura trail	Faturas with NIF and article number
Acquisition value questioned	Old deed not in digital reach	Purchase escritura, stamp records
Share or date inconsistencies	Registry history differs	Certidão, succession documents
Reinvestment doubts	Claimed relief, unclear follow-through	New deed, dates, HPP registration

Response quality is document quality, and the window is the whole game: an answered divergência with clean paper typically resolves into the original or a corrected assessment without drama, while an unanswered one matures into an assessment on AT’s figures, with the deductions stripped and the appeal clock already running. Stripping a €40,000 works claim adds roughly €5,600 of tax at a 28% marginal band, all of it avoidable by uploading the faturas inside the window. Non-residents lose these by correspondence failure more than by substance, one more consequence of the representation setup working or not.

Red flag: responding with narrative instead of paper. The reviewer’s screen wants the fatura, the deed, the certidão; a persuasive letter without attachments reads as an admission dressed politely. Every claim in the return should have been enterable because a document existed, and the divergência is simply the request to produce it.

How are errors corrected, and what do delays cost?

Correction economics reward speed with discounts at every stage: an amendment inside the window costs €0, a voluntary substitute declaration after it carries reduced penalties scaling with delay, and the same error found by inspection inside the 4-year window prices at the full scale with 4% annual interest throughout. Across this market, speed is the whole discount.

The regime, from cheapest to most expensive:

1. Inside the window, to 30 June: file a substitute declaration; the last one filed governs, at zero cost.
2. Late but voluntary, within 30 days of the deadline: minimal penalties, the practical answer for a July discovery.
3. Voluntary, later: reduced fines under the voluntary-correction regime, plus compensatory interest at 4% a year on any underpaid tax.
4. Missed filing entirely: penalties from €200 to €2,500 for the return itself, an assessment built from the notarial feed with no deductions, and the loss of elective benefits, reinvestment relief undeclared, losses not banked for the 5-year carry-forward.
5. Inspection-found errors: the full penalty scale, interest, and the 4-year assessment window’s remaining runway.

The pattern across every stage is that the system prices honesty cheaply and silence expensively, which aligns the rational strategy with the simple one: file on time on the best available figures, correct proactively when the folder later disagrees, and answer letters with documents inside their windows. Cross-border sellers close the loop in their home system afterwards, where treaties credit the Portuguese tax against the domestic bill, the UK mechanics being the template case, and the credit runs on exactly the assessment notes this filing produces. The selling guide places this entire chapter inside the wider exit, deed to declaration to credit, where it belongs from the start of the plan.

FAQ

Frequently Asked Questions

When do I file Modelo 3 after selling Portuguese property? +

Between 1 April and 30 June of the year following the sale, through the Portal das Finanças. A 2026 sale files in spring 2027. The obligation applies to residents and non-residents alike, and it applies even when the sale produced a loss or an exempt gain.

What is Anexo G and what goes into it? +

The capital gains schedule of the Modelo 3 return. For each property sold it takes the acquisition and sale dates and values, your ownership share, the deductible charges and works, and any reinvestment declaration. The tax office computes the gain from those fields; you supply the inputs.

What is Anexo G1 and when is it used instead? +

The schedule for non-taxed disposals, principally property acquired before 1 January 1989, when the current tax code entered force. The sale is declared for the record but produces no tax. Filing the pre-1989 sale in the wrong annex is a classic self-filing error.

Do non-residents file the same form? +

Yes, Modelo 3 with Anexo G, marking non-resident status. Since 2023 the calculation runs on the resident basis, half the net gain at progressive rates, with worldwide income counted for the rate. Non-EU sellers file through the access their fiscal representation or portal registration provides.

When is the tax actually paid? +

The assessment issues after filing, normally by 31 July, and payment falls due by 31 August. Nothing is withheld at the deed itself, which surprises sellers used to systems where the notary retains tax; in Portugal the bill arrives the following summer.

What if I cannot pay the assessed amount at once? +

Instalment plans are available on application, up to 36 monthly instalments for qualifying debts, with interest running on the deferred balance. Applying inside the payment window keeps the file in the ordinary regime rather than enforcement.

What is a divergência letter? +

AT's notice that its data does not match your return: a different sale value from the deed, works it cannot verify, dates that disagree with the registry. It carries a response window, typically 15 to 30 days, and is answered with documents through the portal. Unanswered, the assessment issues on AT's figures.

Can I amend a return I got wrong? +

Yes, by substitute declaration. Inside the filing window an amendment costs nothing; after it, reduced penalties apply for voluntary correction, scaling with delay. An amendment you initiate prices far below the same error found by inspection years later.

Which documents should I keep for the filing? +

Both deeds, the purchase and the sale, invoices for the acquisition charges, every works fatura with your NIF and the property's article, the commission and certificate invoices from the sale, and proof of any reinvestment. AT cross-checks against e-fatura and the notarial feed; documents make the difference.

Does an exempt or loss-making sale still need filing? +

Yes. Exemptions are claimed through the return, not assumed outside it, reinvestment relief in particular dies if never declared, and a loss filed on time carries forward 5 years against future Portuguese gains. Skipping the filing converts both benefits into penalties.