Perhaps this document can help someone out when trying to change their address to Portugal with Finanças:
Instruções de Serviço. Alteração de residência fiscal para PT. Requisitos.pdf (2.6 MB)
Note that it’s actually two documents, one from March and one from May 2022. They are both instructions sent to the heads of Finanças offices and Lojas do Cidadão.
Section 3.1 of the former states that for a foreigner (non-EU/EEA national) to change their fiscal address to Portugal, they need to show a residence document issued by SEF (now AIMA).
Translation of the relevant section (3.1) of the first document
3 - Residence Authorization Titles or equivalent document.
3.1 Change to Resident - Foreign Citizen
Under the terms of paragraph 4 of article 24 of Decree-Law No. 14/2013, of January 28, changes to the registry follow, with the necessary adaptations, the procedures and formalities provided for initial registration.
Thus, at the level of supporting documentation for the change of address of the foreigner to Portuguese territory, there is no difference regarding the documents required for registration. Therefore, the request for a change of address from non-resident to resident must always be accompanied by a document proving residence in Portuguese territory, namely, public deed of acquisition of property for housing, rental contract of property for housing, or work contract.
In the case of a third-country national, holder of a Tax Identification Number (NIF) assigned as a non-resident, even if another document proving residence in Portuguese territory is presented, the interested party must present a residence authorization title (valid at the date of the request), issued by the Immigration and Borders Service (SEF).
The address to be registered must be the same as that on the residence authorization title. If the citizen indicates a different address, they must prove that they have requested the competent entity (SEF) to change their address (the document to be shown must contain the address they intend to update with the Tax Authority). This procedure must also be adopted in situations where the foreign citizen (nationality of a third country) is already registered in the System of Management and Registration of Taxpayers (SGRC), as a resident, and wishes to change the address in Portuguese territory.
The second document was issued shortly thereafter since they realized that it was unreasonable to demand a residency document given the processing delays.
Translation of the second document
Various situations have come to the attention of this Directorate of Services involving delays in processing residence authorization requests by the Immigration and Borders Service (SEF), which have caused constraints due to the fact that the interested parties have been residing in Portuguese territory for some time but still do not have the said authorization title, and thus their fiscal address is not changed (continuing as non-residents until obtaining the document from the competent entity).
Therefore, it is necessary to amend the procedure stated in point 3.1 of Service Instruction No. 90052/2022, Series I (Registration and Change of Individual Taxpayer).
Accordingly, the following information is provided:
Change to Resident - Foreign Citizen
1 - According to the provisions of paragraph 4 of article 24 of Decree-Law No. 14/2013, dated January 28, changes to the registry follow, with the necessary adaptations, the procedures and formalities provided for initial registration.
2 - Thus, at the level of supporting documentation for the change of address of the foreigner to Portuguese territory, there is no difference regarding the documents required for registration.
3 - Therefore, the request for a change of address from non-resident to resident must always be accompanied by a document proving residence in Portuguese territory, namely, public deed of acquisition of property for housing, rental contract of property for housing, work contract, or document issued by any public entity.
4 - In the case of a third-country national, holder of a Tax Identification Number (NIF) assigned as a non-resident, any of the following documents must be presented where the address to be indicated as fiscal domicile is expressly stated:
a) Residence authorization title (valid at the date of the request), issued by SEF;
b) Document of expression of interest or request issued by the registration platforms used by SEF, in cases of requests made under articles 88, 89, and 90-A of Law No. 23/2007, of July 4, in its current wording (Order No. 12870-C/2021, of December 31, from the Presidency of the Council of Ministers);
c) Document proving the scheduling at SEF or receipt proving a request made in all other situations of pending processes at SEF, namely grants or renewals of residence authorization, based on the general regime or exceptional regimes (Order No. 12870-C/2021, of December 31, from the Presidency of the Council of Ministers);
Note: Whenever the documents referred to in items a), b), and c) do not include the address, it may be changed provided that any of the documentary proofs referred to in point 3 is also presented:
4.1 - If the citizen indicates an address different from the one in the documents issued by SEF, they must prove that they have requested this entity to change their address (the document to be displayed must contain the address they intend to update with AT). This procedure must also be adopted in situations where the foreign citizen is already registered in the Taxpayer Management and Registration System (SGRC), as a resident, and wishes to change the address in Portuguese territory.
5 - Point 3.1 of Service Instruction No. 90052/2022 is hereby revoked.
In particular 4 c) of the latter instruction also accepts a “document proving the scheduling at SEF or receipt proving a request made in all other situations of pending processes at SEF” which to me seems to apply to all GV applicants (whether they have pre-approval or not). Then again I’m not a lawyer.