Unlocking SAF-T: Standard Audit File for Tax

• Austria 

The Austrian Ministry of Finance introduced SAF-T in 2009. It is one of the earliest countries which took first steps in this regard. For the time being, the taxpayers are not obliged to submit SAF-T reports on a regular basis (monthly, quarterly or yearly). If the ministry of finance requires an audit, then the relevant taxpayers shall be prepared with electronic SAF-T documents. Requested format is XML, and this XML should contain; general ledger, inventories, accounts receivables, accounts payables and assets. 

• Czechia 

Czechia introduced the SAF-T report starting from 2016. It includes all registered taxpayers in Czechia. SAF-T report should contain VAT Control Statement which includes basically VAT returns. Czech taxpayers shall submit their monthly VAT statements on the 25th day after the reporting period for the following month.  

Czechia also implements penalties for non-compliance. These penalties may be caused due to the unfulfilled VAT Control statements or incorrect submissions. Fines can change between CZK 1.000 – CZK 50.000.  

• France 

Although the structure is highly similar to SAF-T and the main aim was creating the French version of SAF-T, its local name is called FEC (Fichier d’Ecritures Comptables). It was introduced by French authorities in the beginning of 2014. It is not mandatory yet, however, the taxpayers shall present the report on request of the authorities for an accounting year in a .txt format. There are 18-22 fields depending on the regime for fulfilment per accounting entry. After the audit notice, the taxpayers have 15 days for the submission.  

• Hungary 

The Hungarian Ministry of Finance (NAV) introduced SAF-T in 2021. It is not mandatory yet, however, taxpayers should present on-demand of the tax authority. SAF-T Hungary is a different type of reporting than the Real Time Invoice Reporting (RTIR) in Hungary. The report shall be in the XML format. There are 3 main types of requested data: 

1. Master Data 
2. Transactional Data 
3. Reporting Data 

The Hungarian tax authority (NAV) has been planning to make the SAF-T report mandatory, however, there is still uncertainty on the obligation date.  

• Lithuania 

The SAF-T report in Lithuania, known as i.MAS, was introduced in 206 for the large taxpayers. Gradually it became mandatory year by year for the businesses depending on their size, but starting from 2020, the obligation became effective for all taxpayers. Required file format is XML and this XML shall be presented on demand of the Lithuanian authority. 

There are three main structures in i.MAS; 

1. i.SAF: It includes sales and purchase invoices and the report shall be submitted on a monthly basis on the 20th of the month for the period of reporting.  
2. i.VAZ: It contains the transport or consignment document for the domestic movements of the goods within the country. 
3. i.SAF-T: It is requested only for the resident businesses and their accounting transactions should have a place in the report.

• Luxembourg 

The SAF-T report in Luxembourg, or as known as FAIA (Fichier Audit Informatisé) was introduced by the ministry of finance in 2011. The report submission is not mandatory yet, but upon the ministry of finance’s (AED) request, the taxpayers are obliged to provide a SAF-T report.  

The requested file format is XML; however, the AED also accepts other formats such as; XBRL and DBF. This regulation only applies to resident taxpayers, meaning the non-resident companies are exempt from the obligation. Resident taxpayers’ standard chart of accounts shall be reported upon the AED’s request. There is also a threshold of €112.000 annually. The SAF-T report includes; 

• Header 
• Masterfile (General Ledger Accounts, Customers, Suppliers) 
• General Ledger Entries  
• Source Documents (Sales & Purchase Invoices) 

There are 3 schemas introduced within the scope. These are; 

1. FAIA_Full Schema: For those taxpayers which have the full accounting software and integrations 
2. FAIA_Reduced: For those taxpayers who use accounting software and invoicing software separately 
3. FAIA_Reduced B: For those taxpayers who uses only accounting software 

The AED also have fines and penalties for the non-compliance. These penalties may be implied either up to €5.000 per breach in total; or on a daily basis from €50 to €1.000.  

• Norway 

The Norwegian tax authority (Skatteetaten) introduced SAF-T regulation in 2017 on voluntary basis. Starting from January 2020, it is required for those taxpayers which have turnover more than NOK5 million on request by the Skatteetaten.  

The required file format is XML, and the report should include; 

• Header 
• Master Files (General Ledger Accounts, Customers, Suppliers, Tax Table, Analysis Type Table, Owners) 
• General Ledger Entries 

• Poland 

The Polish ministry of finance introduced SAF-T on July 2016 for the large taxpayers. Gradually, it became mandatory for all taxpayers starting from 2018. The file types are named as JPK (Jednolity Plik Kontrolny). JPK VAT was replaced with monthly JPK_V7M and quarterly JPK_V7K starting from 2020. This SAF-T report is subject to resident and non-resident taxpayers. There are seven different JPK types. These are; 

JPK_KR: Accounting books 

JPK_MAG: Warehouse or Storages 

JPK_WB: Bank Statements 

JPK_VAT: (or JPK V7M/K): VAT Returns 

JPK_FA: (VAT Invoices) 

JPK_PKPIR: (Revenue and expense tax books) 

JPK_EWP: (Revenues registry) 

Only JPK_V7M/K reports are subject to be submitted to the tax authority by the 25^th day of the month after the reporting period. Other JPK files are on-request by the authority. The file format is XML, and the taxpayers shall have a USB token for the digital signature. There are penalties for the non-compliance or incorrect submissions.  

• Portugal 

SAF-T report was introduced in Portugal back in January 2008. There are 2 types of submissions. These are monthly VAT return and yearly summary reporting in the scope of the SAF-T. Autoridade Tributária (AT), the Portugese Ministry of Finance, requires this report by the 20^th of the month after the reporting period. The required report format is XML as in most of the other SAF-T solutions. There are three main Portugese ledgers in this scope: 

• Accounting 

In order to create the electronic format of the accounting files for SAF-T PT, accounting systems shall record the information. Taxpayers are able to fulfil the file on either monthly or annual basis. These reports shall include; list of items, information of the customers and suppliers, chart of accounts and the accounting entries.  

• VAT Reporting  

The electronic VAT returns shall be submitted by the 5^th of each month in the scope of the SAF-T PT. The tax authority requires these files to be prepared sequentially. Besides, the authority obliges the encryption of these files via electronic signature of the previous invoice in terms of controlling purposes for the file generation processes.  

• Transport Documents 

When it comes to the movements of the goods, the Portuguese Tax and Custom Authority requires real time data via receiving the code automatically. This code is integrated with the transport document so that the movement of goods could be enabled.  

• Romania 

The Romanian Tax Authority ANAF (National Agency for Fiscal Administration) introduced SAF-T solution and the regulation became mandatory in phases as below: 

• January 2022: Large taxpayers 
• January 2023: Medium taxpayers 
• January 2025 Small taxpayers 

There are 3 types of report within the scope of the SAF-T in Romania. These are: 

• D406 Declaration: This report shall include tax and accounting information on a monthly or quarterly basis. 
• D406 Asset Declaration: Depending on the financial year, annual asset information shall be reported to ANAF. 
• D406 Stock Declaration: On-request of ANAF, stock information shall be submitted within the 30 days of the request.  

The D406 declaration shall contain below: 

• Header 
• Master Files (General Ledger Accounts, Customers, Supplier, Tax table, OUM table, Movements, Products, Analysis types, Warehouse, Movements, Fixed Assets Ledger) 
• General Ledger 
• Source Documents (Sales & Purchase invoices, Payments, Stock Movements, Fixed Asset Movements) 

Before the submission to ANAF, taxpayers shall validate the document via DUK Integrator which is provided by ANAF. After the validation with the DUK, taxpayers are able to make their submission successfully.  

• Turkiye (e-Bookkeeping) 

Turkish Revenue Administration (GIB) introduced e-bookkeeping back in 2011. The regulation gradually became mandatory depending on the turnover of the taxpayers. The required file format by TRA is XML, and this report shall include general journals, general ledgers and ledger summary reports. The frequency of the submission is on a monthly basis. Real person taxpayers must have a qualified electronic sertificate or a financial stamp, while the legal personality taxpayers must have a financial stamp.  

The advantages of e-bookkeeping in Turkiye are saving time and cost, archiving the records electronically, speeds the process of notary approval. 

• Ukraine 

SAF-T UA has been introduced in 2021, but the taxpayers would submit the SAF-T report on a voluntary basis starting from January 1, 2023. The required file format is XML as in most of the SAF-T countries. It is planned to phase out of the obligation for large taxpayers from January 2025, and for all taxpayers from January 2027. The taxpayers shall submit the report within two days of the notice.  

The report shall contain;  

• General Ledger Entries 
• Sales Ledger 
• Fixed Assets 
• Cash Receipts 
• Intangible Asset Movements 
• Tax Reconciliations