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Bulgaria SAF-T 2025 launch doubts

National Revenue Agency progresses OECD-based Standard Audit File for Tax of transactional-level VAT data

Bulgaria is preparing to join other countries implementing SAF-T, the OECD-backed standard schema for the exchange of information between tax payers and authorities. The first version of the Bulgarian SAF-T XSD schema is now available.

For 2025, Bulgaria stocks & fixed asset reporting is being introduced on a quarterly basis.

With the support of the European Commission last week, it has been reviewing existing EU implementations – including France, Poland and Portugal – for best practises before a launch potentially in 2025. Although the hoped-for January launch now looks unfeasible given the necessary six-months’ notice that would be required.

This will include reviewing ledger formats, scope of data requests and transmission technical specifications. The aim is to simplify tax audits, and reduce manual work required of tax payers in the compliance process.

The regime will apply to resident and non-resident tax payers (with a Bulgarian VAT number). It will initially likely be voluntary.

Reports will be monthly for sales, purchases, cash and general ledger transactions.  Annual reporting for fixed assets.

Phased introduction 2025

It is planned to announce in later 2024 the formats and phased launch schedule, based on v2 of the OECD with XSD schema format. This indicates a likely launch of 2025 for the largest taxpayers:

  • 6 months voluntary compliance
  • 12 months largest taxpayers
  • 12-24 months medium and small taxpayers

Whilst SAF-T was launched over 10 years ago to standardise transaction-level data exchange for VAT reporting, most countries that have implemented it – around 10 in the EU – have diverged from the recommended schema. This creates problems for companies trading across the Single Market and the interoperability & reusability of code and processes for reporting. VATCalc’s transaction-level VAT Filer, which can produce European SAF-T reports which are fully reconciled to VAT returns.

Bulgaria e-invoicing plans are still to emerge following a public consultation in 2021.

Austria is planning to relaunch its version of SAF-T. Denmark SAF-T is due in 2024. Ukraine will implement SAF-T from 2025.

OECD Standard Audit File for Tax (SAF-T)

The OECD launched v1 of SAF-T as a standard for tax authorities and taxpayers to efficient exchange information. It is XML-based. Over 10 European countries have already adopted it.

  1. General Ledger: journals;
  2. Accounts Receivable: customer master files; invoices; payments;
  3. Accounts Payable: supplier master file; invoices; payments;
  4. Fixed Assets: asset master files; depreciation and revaluation; and
  5. Inventory: product master files; movements.

Standard Audit File for Tax SAF-T countries

Country (click for details) Date Scope
13 Ukraine Jan 2025 Phased 2025 to 2027 implementation
12 Bulgaria 2025 ? Phased introduction over two years
11 Denmark Jan 2024 Phased implementation from 2024
10 Romania Jan 2022 Mandatory monthly filings initially large taxpayers (due Jan 2023)
9 EU OSS & IOSS Jul 2021 On-demand for sellers, marketplaces or Intermediaries
8 Norway 2020 Replaced VAT return 2022
7 Angola 2019 On-demand
6 Lithuania 2019 On-demand; residents and non-residents above €30,000 sales threshold
5 Poland 2016 Mandatory, monthly replaced VAT return Oct 2020
4 France 2014 On-demand
3 Luxembourg 2011 On-demand
2 Austria 2009 On-demand
1 Portugal 2009 Monthly for residents and non-residents (Jun 2022)

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