1st round Romanian Standard Audit File for Tax returns delayed to 1 January 2023
The original list of taxpayers subject to monthly SAF-T reporting have been given a further six months soft landing phase. This means their 2022 reports will not be due until 31 January 2023 instead of 31 July 2022. This is based on feedback from users and technical delays. The deadline for each subsequent return will be reducing from 12 months down by 1 month each month. So the January 2022 return will be due in 11 months time.
2nd round of taxpayers added to Declaration 406 requirements; given 6-month soft landing for first filing
The Romanian National Agency for Fiscal Administration (ANAF) has named an additional round of large taxpayers who will join the new Standard Audit File for Tax (SAF-T) D406. These 1,500 will be required to submit their first declarations by 31 July 2023 overing (a six-month grace period). Taxpayers on the original list must submit their first returns by 31 January 2023 (following above delay).
Non-resident taxpayers with a Romanian VAT number may be required to complete SAF-T from January 2025 – but to be confirmed. RO e-invoicing is starting in January 2022.
There had already been a 3-month moratorium for the launch for large taxpayers. All taxpayers should be on the scheme by the start of 2025. This includes non-resident businesses with a Romanian VAT registration.
There is a reduced data set requirement for non-resident VAT registered businesses.
SAF-T in Romania is known as Declarației informative (Informative Statement) D406 return, and is in XML format. Voluntary testing is now underway ahead of the 2022 mandatory launch. It will be phased in between January 2022 and January 2025 – subject to the six-month grace period. Romania e-invoicing has been discussed for 2022 implementation, but no further details
Check which countries have implemented SAF-T.
2023 to 2025 phased implementation
- Jan 2022 – large taxpayers first wave (12-month soft landing to 31 Jan 2023)
- Jul 2022 – large taxpayers second wave (6-month soft landing to 31 Jan 2023)
- Jan 2023 – mid-sized taxpayers
- Jan 2025 – small taxpayers
- Jan 2025 – non-resident taxpayers
- Romanian SAF-T filing obligations – monthly reporting
D406T returns will be due on a monthly basis in line with the VAT return obligations. There will be an initial 6-month grace period where submissions do not have to be completed to the new timetables. The D406T is due by the final day of the following month. For taxpayers with turnover not exceeding RON500,000 per annum, this is quarterly in line with their VAT filing obligation. There is also:
- Annual reporting of capital or fixed assets, due by the following 31 January; and
- On-demand stock movements reports should be available within 30 days of a request from ANAF.
The first returns for large taxpayers which are published on ANAF’s website, will therefore by due in February 2022 – but with an optional six-month grace . No implementation date for medium-sized companies has been made public. Small enterprises will start in January 2025.
SAF-T D406T structure
ANAF have been consulting with business groups on the development of the transactional-based reporting obligation. It will follow the OECD model (v2.0). It has now issued speficiations, including:
- SAF-T_Romania_SchemaDefinitionCodes.xlsx: the structure of the Romanian SAF-T format
- Romanian_SAF-T_Financial_Schema.xsd – the schema to be adopted under the XML format
- Annex SAF-T – Structura_D.docx – the tax office’s validation rules
The proposed return is structured as follows:
- Header – company details and software used for preparation
- Mater Files
- General Ledger Accounts
- Customer details
- Tax table
- OUM table
- Analysis Type Table
- Product details
- Warehouse inventories
- Fixed assets ledger
- General Ledger – transaction-level details to assist in tax assessment
- Source documentation
- Sales invoices
- Purchase invoices
- Movements of stocks
- Fixed asset movements (due annually)
Voluntary reporting started in August, and large taxpayers will be mandated to submit SAF-T filings from the start of 2022. It is expected that businesses will submit three ledgers on a monthly basis (journals; receivables; and payables). A fixed ledger will be required annually. The fifth ledger, warehouse stocks, will only be on demand.
How to compile the D406 statement
- Prepare the XML files in accordance with the listing above
- Use a structure verification tool to be provided by ANAF to validate the strucuctures
- Create D406 in PDF format with XML attached along with ANAF-issued digital signature of the taxpayer
- Ensure receive ANAF electronic receipt of upload
How to submit SAF-T D406
Taxpayers have three options for filing their XML SAF-T D406:
- From adapted ERP and accounting information;
- Using an XML editor to convert accounting information
- Third-party specialist service provider who can extract, prepare and submit the return on the taxpayer’s behalf.
SAF-T by OECD to harmonise tax data exchange
SAF-T is an OECD developed standard schema for the exchange of data between tax authorities and businesses. It was developed in 2005, and has been so far adopted in: Poland; Norway; Portugal; France; Luxembourg; Austria; and Lithuania. Hungary is looking to be the eighth country in two years’ time.
Standard Audit File for Tax SAF-T countries
|Country (click for details)||Date||Scope|
|12||Ukraine||Jan 2023||Phased 2023 to 2027 implementation|
|11||Romania||Jan 2022||Mandatory monthly filings initially large taxpayers (due Jan 2023)|
|10||Hungary||Likely 2023||Potential introduction SAF-T HU|
|9||EU OSS & IOSS||Jul 2021||On-demand for sellers, marketplaces or Intermediaries|
|8||Norway||2020||Replaced VAT return 2022|
|6||Lithuania||2019||On-demand; residents and non-residents above €30,000 sales threshold|
|5||Poland||2016||Mandatory, monthly replaced VAT return Oct 2020|
|1||Portugal||2009||Monthly for residents and non-residents (Jun 2022)|