What is a Standard Audit File?
A Standard Audit File (SAF) is a set of data as found in a general ledger chart of accounts and the taxpayer’s accounting evidence generated in a specific electronic format. The general SAFT model is developed by the Organization for Economic Co-operation and Development (OECD). The aim of implementing this Audit File is to increase the efficiency of control activities conducted by tax and fiscal authorities. Poland is the sixth country in line among other EU member states (after Portugal, Luxemburg, Austria, Lithuania and France), that has implemented this solution into its legal order
What is contained in Standard Audit Files?
The website of the Ministry of Finance presents structural schemes which should be included in Standard Audit Files. On its basis Standard Audit Files are classified under the following 7 structures, which should contain i.e.:
– accounting records,
– bank account statement,
– VAT registry for sales and purchases,
– VAT invoices,
– tax revenue and expense ledger,
– journals for recorded revenue.
It should be pointed out that the scope of data included in individual structures is closely linked to the applicable Polish tax regulations, so there is no possibility to transmit directly the standard audit file solutions for use in other EU member states.
When Standard Audit Files should be submitted?
In principle, transmission of data through the Standard Audit File format should take place at the request of tax authorities. However, there is one exception from this rule.
Monthly information on keeping a VAT registry for sales and purchases will have to be submitted without a formal notice. Such information must be submitted until the 25-th day of the month following each subsequent month. Also taxpayers who chose to effect tax settlements in a quarterly manner would be required to submit SAF reporting data from VAT registry, on a monthly basis.
The introduction of SAF and transitional periods
The obligation to report data in a unified format, namely the Standard Audit File may be enforced on the date on which the new regulations come into effect (starting as of 1 July 2016) only with regard to large businesses. Whereas, micro-, small, and medium-size businesses will have transitional periods.
A large business is an entity that during one of the two recent accounting years:
– employed on average not less than 250 employees on an annual basis, or
– fulfilled both of the following conditions:
In turn, microbusinesses are defined as those that during one of the two recent accounting years:
– employed fewer than 10 employees and
– acquired an annual net turnover from selling goods, products and services, including financial operations not exceeding the equivalent value of EUR 2 million in zlotys, or its balance sheet assets resulting from a balance sheet prepared for one of the two accounting years ended did not exceed the equivalent value of EUR 2 million in zlotys.
All other business entities that do not fall within the definition of a so called large business, and where simultaneously their employment, and net turnover or total assets exceed the threshold established for microbusinesses should be classified into small or medium taxpayers.
The obligation of reporting data in SAF format for each business category:
|Status||VAT registry||Other SAF structures|
|large business||on a monthly basis, for the first time by 25 August 2016 (for July 2016)||At the authority’s request until 1 July 2016.|
|small and medium-size businesses||on a monthly basis, for the first time by 25 February 2017 (for January 2017)||At the authority’s request until 1 July 2017.|
|microbusiness||on a monthly basis, for the first time by 25 February 2018 (for January 2018)||At the authority’s request until 1 July 2018.|
Are foreign entities registered in Poland for VAT purposes required to submit SAF ?
Indeed entities who do not have their registered office or place of business in Poland, but perform VAT settlements in Poland are also required to submit SAF. However, in their case the scope of using SAF is limited to the following two structures:
– VAT registry for sales and purchases (submitted on a monthly basis without notice),
– VAT invoices (at the authority’s request).
However it is important to know that determination of the status of a foreign entity (large, medium, small or micro-business) requires consideration of its business operations as a whole and not just those transactions which are taxable in Poland.
Sanctions for failure to submit data through SAF
In the event of failure to deliver the Standard Audit File on time, or its transmission in a defective manner may be exposed to a risk of fiscal-penal sanctions. In 2016 the amounts of penalty rulings in accordance with the fiscal-penal code varied between PLN 616.70 and PLN 17,760,960.00.
Generating SAF with the use of accounting software
It should be noted that in order to meet the obligations associated with launching Standard Audit Files businesses will need to update their accounting software in a way allowing them to generate files based on the appropriate SAF structures. Therefore, our recommendation is to get in touch with your accounting software supplier in the first place.
Unfortunately, as it follows from our information the majority of software producers did not give access to this function in the offered products.
Generating a SAF VAT file without any interference into SAP
Modification of accounting software, specifically with regard to SAP systems is a costly and time-consuming procedure. However, it’s worth noting that the above mentioned modification is not required, especially in the case of foreign entities which have the obligation of submitting SAF only to a very limited extent.
The provisions on implementing SAF do not specify the manner of generating SAF, but only provide the scope of data to be reported in each file. This means that SAF may also be created on an external basis with the use of separate software and it may be outsourced to other suppliers.
How can we help?
For easier fulfilment of the above mentioned obligations a team providing complex SAF services was set up for you to deal with the following i.e.:
– establishment of the entity’s status (micro-, small, and medium-size businesses);
– fixing the date of assuming SAF reporting duties by an entity;
– preparation (generation) of a SAF VAT file based on data received from the customer (i.e. in spreadsheet format);
– preparation (generation) of SAF Invoices based on data received from the customer (i.e. invoices in pdf scanned format);
– verification of SAF files including compatibility tests (i.e. between a SAF VAT file and a VAT-7 statement),
– submitting data through the Standard Audit File to the tax authorities.