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The Standard Audit File for Tax (SAF-T) is a new reporting requirement for taxpayers and it reflects the international standard for the electronic exchange of accounting data between companies/organisations and tax authorities, containing information on taxpayers' accounting and tax data.
SAF-T’s main role is to standardise the transfer of information between tax administrations and taxpayers, offering benefits to both parties. SAF-T involves the regular reporting of a set of information (initially, in addition to tax returns - in a predefined format) that facilitates the review of taxpayers' operations by tax authorities.
Romania introduced the SAF-T reporting requirement as of 1 January 2022, for Romanian legal entities and the Romanian entities without legal personality of foreign companies that use the double-entry accounting system, as well as for non-resident companies registered for VAT purposes in Romania.
The SAF-T structure in Romania contains more than 390 mandatory tax and accounting elements that should be reported by taxpayers.
The SAF-T file will be used by tax authorities as evidence during tax inspections to determine tax compliance by taxpayers, the purpose of tax inspections being, among others, to verify the matching between the data in the tax returns and, respectively, in the accounting and tax records of taxpayers/payers, including the information in the SAF-T File.
Therefore, preparing for SAF-T is crucial, as all the accounting and tax-related information should be reported monthly/quarterly/annually or upon request.
Large taxpayers were required to submit the SAF-T file (using the D406 form) in February 2022 for January 2022. Medium-sized taxpayers will be required in 2023, followed by small taxpayers in 2025.
The date when the SAF-T file will become mandatory depends on the taxpayer categories, as follows:
Large taxpayers (in this category at 31 December 2021) had the obligation to submit the D406 statement as of 1 January 2022;
Medium taxpayers (in this category at 31 December 2021) will have the obligation to submit the D406 statement as of 1 January 2023;
Small taxpayers (in this category at 31 December 2021) will have the obligation to submit the D406 statement as of 1 January 2025;
By way of exception, financial-banking institutions and insurance / reinsurance companies (including investment management companies and managers of alternative investment funds / alternative investment funds, entities authorized, regulated and supervised by the Financial Supervisory Authority), (large taxpayers at 31 December 2021) as of 1 January 2023
Taxpayers who were required to submit the D406 statement, according to the reference data, and subsequently fall into a category for which the reference date for filing the return was not met, will continue to report the SAF-T file by submitting the D406 statement.
In the category of taxpayers who have the obligation to submit the SAF-T file to the fiscal body are also included non-resident companies that have a VAT registration number in Romania (e.g. taxpayers registered through direct registration, taxpayers registered through a tax representative, fixed establishments)
Taxpayers will submit the D406 Informative Statement monthly or quarterly, in line with the applicable periods for VAT reporting. Taxpayers not registered for VAT purposes will lodge the SAF-T file quarterly.
The D406 Informative Statement will be submitted electronically, with the following submission deadlines to be observed:
by the last calendar day of the month following the reporting period (calendar month/quarter, as appropriate, for information other than Inventories and Fixed Assets).
by the deadline for filing the financial statements for the financial year, in the case of D406 Informative Statement - Fixed Assets.
within the deadline established by tax authorities, which cannot be earlier than 30 calendar days from the date of the request, in the case of the Informative Statement D406-Inventories.
The size of D406 cannot exceed 500 MB. If the form exceeds this limit, taxpayers will submit the data using modal reporting (reporting the data in several portions - several D406 returns in the same month for each taxpayer). If a taxpayer finds certain errors in the D406 statement initially submitted, it may file a rectifying statement.
Failure to submit the SAF-T File within the statutory deadlines or incorrect or incomplete submission of the SAF-T File, as determined by the National Agency for Fiscal Administration (ANAF), will entail non-compliance penalties, unless the SAF-T file is corrected by certain deadlines.
Taxpayers will benefit of a grace period, as follows:
Preparing for SAF-T does not involve only the extracting of data from the ERP system and filing it to ANAF in the required format (i.e. *.xml), but certain preparatory steps as well, during which checks are performed on the accuracy and integrity of the SAF-T files you will submit.
PwC has a dedicated team who can assist you in preparing for the new SAF-T reporting. This also includes access to the application we provide, which processes and validates the data to be reported in the SAF-T file and generates the file in an *.xml format. For more information on the steps for preparing for SAF-T and the presentation of the application that verifies the data and prepares the SAF-T file, our dedicated team is at your disposal.