When an international public tender in Portugal requires submission of the Central Register of Beneficial Ownership (RCBE), foreign entities without a Portuguese tax identification number may submit an equivalent document issued by the competent authority in their country of origin.
In recent years, it has become increasingly common for international public tender notices published in Portugal to require, among the documents to be submitted, a declaration from the Central Register of Beneficial Ownership (RCBE).
This requirement, however, often raises questions among foreign entities wishing to participate in public tenders in Portugal.
It is important to clarify that where a bidding entity does not hold a Portuguese tax identification number — and, consequently, cannot be registered via the portal https://rcbe.justica.gov.pt — it is acceptable to submit an equivalent document issued in its country of origin.
By way of example:
- Déclaration des bénéficiaires effectifs, in France;
- Declaration of Beneficial Ownership Information, in English-speaking countries.
The same principle applies to equivalent documents from other EU Member States or from third countries.