Submission of the Standard Audit File for Tax purposes SAF-T tax control file – the dates from which various categories of taxpayers have to submit the SAF-T and the related grace periods

In detail

The National Agency for Fiscal Administration (ANAF) president published on 16 September 2021 the draft order establishing the SAF-T rules.

The date from which SAF-T submission becomes mandatory varies by taxpayer category, as follows:

• Large taxpayers as at 31 December 2021 have to submit Informative Statement D406 as of 1 January 2022;

• Medium taxpayers as at 31 December 2021 have to submit D406 as of 1 January 2023;

• Small taxpayers as at 31 December 2021 have to submit D406 as of 1 January 2025;

• As an exception, financial-banking institutions and insurance/reinsurance companies (including entities authorised and regulated by the Financial Supervisory Authority) classified as large taxpayers as at 31 December 2021 have to submit D406 as of 1 January 2023.

When a taxpayer changes size categories, it has to submit the D406 according to the deadline applicable for the new size category.

Non-resident companies registered in Romania for VAT purposes (taxpayers registered by direct registration, taxpayers registered by tax representatives and permanent establishments) also have to submit SAF-T.

Reporting method and deadlines

• Taxpayers will be required to submit the SAF-T through D406 on a monthly or quarterly basis by following the applicable tax period for value added tax (VAT). Taxpayers not registered for VAT purposes will submit SAF-T quarterly.

• The SAF-T has to be submitted in electronic format with the following deadlines:

  • By the last calendar day of the month immediately following the reporting period (calendar month/quarter, as appropriate, for information other than Stocks and Assets).

  • By the deadline for submitting the financial statements for the financial year in the case of D406-Assets.

  • Within the term established by the fiscal body, but no less than 30 calendar days as of the date of the request, in the case of D406-Stocks.

Taxpayers will benefit from a grace period of:

• six months for the first reporting, five months for the second, four months for the third, three months for the fourth and two months for the fifth reporting for large taxpayers required to submit the SAF-T on a monthly basis;

• three months for the first reporting for taxpayers required to submit the SAF-T on a quarterly basis.

The takeaway

The date from which the submission of the SAF-T becomes mandatory varies by taxpayer category: large taxpayers submit Information Declaration D406 as of January 2022; medium and financial-banking institutions and insurance/reinsurance companies submit it as of 2023; small taxpayers as of 2025.

Large taxpayers will receive a grace period of six months for the first SAF-T reporting.

PwC has a dedicated team ready to assist you in preparing for the new SAF-T reporting. That includes access to our software application, which processes and validates the data to be reported in the SAF-T and generates the file in * .xml format.

For further information about the SAF-T and our software application, our dedicated team is at your disposal.