Understanding the Upcoming SAF-T UA Requirements for Taxpayers in Ukraine

As part of ongoing efforts to enhance tax compliance and streamline audit processes, the Ukrainian government is implementing new requirements for large taxpayers concerning Standard Audit Tax Filings (SAF-T UA). Here’s what you need to know about these requirements and how to prepare for them.

Key Dates and Requirements

1. From 27 August 2021: Large taxpayers are required to submit Standard Audit Tax filings upon request by the Ukrainian tax authority. These filings must be submitted no later than two business days following the receipt of the request as part of an audit (para. 85.2, the TCU).
2. From 1 January 2025: It will become mandatory for all large taxpayers to submit Standard Audit Tax files as per Draft Law No. 6255 dated 2 November 2021.
3. From 1 January 2027: All VAT payers will be required to submit these filings, as mandated by Draft Law No. 6255.

Preparing for SAF-T UA Submissions

The Ukrainian State Tax Service (STS) is updating the taxpayers’ electronic cabinet for SAF-T UA, anticipating an increase in requests following the resumption of tax audits on 8 January 2023. Large taxpayers should be prepared to receive and respond to these requests promptly.

Main Information Provided in SAF-T UA

The SAF-T UA submission includes extensive detailed information, structured as follows:

1. Accounting Policies and Approaches:
   • Detailed description of accounting policies and methodologies used.
2. Business Transactions:
   • Comprehensive details, including transaction coding and characteristics.
3. Accounting and Tax Information:
   • Transactions by date, number, source document name, and amount.
4. Source Documents:
   • Including accounting certificates and other relevant documentation.

SAF-T UA Structure

The structure of SAF-T UA is outlined in Order No. 561 dated 15 September 2020 and includes the following sections:

1. Title: Basic information about the taxpayer.
2. Directories:
   • Accounting policies, transaction directories, owner information, balance sheets, counterparties, products, inventories, and non-current assets.
3. Journal of Accounting Records:
   • General information on large taxpayers (LTP), including establishment date, software, authorized persons, owners, and contacts.
   • Detailed accounting transactions.
4. Accounting Records Documentation:
   • Information on sales, acquisitions, non-sale payments, inventory transactions, non-current assets, and source documents.
5. Tax Differences:
   • Any tax differences an entity may have.

Key Issues and Preparatory Efforts

1. Software Readiness: Ensure that the software used by the taxpayer can generate SAF-T UA files accurately.
2. Extensive Information Requirements: Be prepared to provide detailed information and support data, as specified in the extensive list provided in the annex to Order No. 561.
3. Source Documents: All accounting data must be backed by source documents, either in electronic form or, if not required electronically, in Adobe PDF format.
4. Administrative Documents: Copies of administrative documents related to the approval of accounting policies and other detailed information must be submitted along with SAF-T UA.
5. Tight Deadlines: The information must be provided within two business days following a request during an audit by the STS.

Main Preparatory Actions

1. Software for SAF-T UA Submission:
   • Ensure the availability and functionality of software capable of generating and submitting SAF-T UA files.
2. Creation of SAF-T UA Archives:
   • Maintain comprehensive archives of SAF-T UA data for the period of the State Tax Service audit.
3. Checking SAF-T UA Generated Files:
   • Regularly check the generated SAF-T UA files for accuracy and completeness to ensure compliance with the requirements.

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As the deadlines approach, it is crucial for large taxpayers and VAT payers in Ukraine to prepare thoroughly for these new filing requirements to ensure compliance and avoid penalties.

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