Any entrepreneur who uses computer software for financial and accounting records will have the obligation of providing (upon request) data from the accounting books and evidence in the form of a Standard Audit File for Tax (known as SAF-T).
Who does this concern?
For now, the obligation is binding for big companies, defined as those who employ over 250 people. However, by the end of June 2018, smaller businesses will be able to provide SAF-T files voluntarily.
From July 2018, small and medium-sized companies will also have to comply with a request to provide, in the formm of SAF-T, data pertaining inter alia to: accounting books, warehouse records, bank statements, simplified records and VAT invoices.
Monthly, mandatory reporting of VAT records
With the introduction of SAF-T, entrepreneurs who keep their financial reocrds in electronic form have been tasked with a new obligation; the are required to send the reports on their VAT records monthly, also in an electronic file. Such a record must include all the data necessaty to identify the subject and tax basis, as well as the amount of tax due, amount of input tax reducing the amount of tax due and the amount payable to the tax office or reimbursement from the office and other data required for the proper drawing up of the tax return.
These monthly reports are due by the 25th of each month, without any prompting from the tax authorities. The obligation came into being on 1 January 2017 for small and medium-sized businesses, and a year later (1 January 2018) for micro-enterprises.
What is the Standard Audit File?
SAF-T is a database (collection of data) which consists of the information systems of any given entrepreneur. It should include information on business operations for the period in question, in a format allowing for easy processing (XML) and have a clear layout.
What data should a SAF-T file include?
The Polish Ministry of Finance has prepared a set of reporting formats and data required (structures) for different types of tax books and accounting evidence. The structures are as follows:
- accounting books JPK_KR
- bank statement JPK_WB
- warehouse (adoption from the outside, exit, internal expenditure, movements in the stock) JPK_MAG
- records of the purchase and sale of VAT JPK_VAT
- invoices (the invoices) JPK_FA
- tax revenue and expense ledger JPK_PKPIR
- records of revenue JPK_EWP
and are available at the website of the Ministry.
SAF-T data standards include, among other records, details of receipts and reports from cash registers, as well as records for excise duty and currency exchange offices.
A SAF-T file prepared to show stock turnover would, for example, include the prices of goods, measurement units, the value of the goods, their consignees or invoice numbers. The software used by the entrepreneur should be able to select such data and compile it into a SAF-T file acceptable to the tax authorities.
As has already been mentioned, the deadlines for implementing SAF-T are different depending on the size of a company.
For large companies (meaning those employing over 250 personnel and with at least 50 million Euro turnover) it means that, starting at 1.01.2017, they are obligated to be ready to provide SAF-T files upon request of the authorities, in the form of a single file. Every month, without any requests, the need to send reports from the VAT records by the 25th of the month.
The monthly VAT reports are also obligatory for small and medium-sized companies (those with fewer than 250 employees), including foreign companies. Until the end of June 2018, they may voluntarily send SAF-T files upon request. After this date (from 1 July 2018), providing SAF-T files when the tax authorities request they do so will be mandatory.
Micro-enterprises, with fewer than 10 employees and turnover under 2 million Euro, should start sending out the monthly reports on VAT records unprompted from January 2018. Until the end of June 2018, they may voluntarily send SAF-T files upon request. After this date (from 1 July 2018), providing SAF-T files when the tax authorities request they do so will be mandatory.
How should I prepare a SAF-T file?
The introduction of the SAF-T format makes for necessary changes in your accounting and financial software. This also includes programs used for keeping track of e.g. storage – the files they produce must be SAF-T-compliant and consistent with the formats required by the Ministry of Finance.
In theory, it should be possible for you to introduce the required software changes on your own, but you would need an IT technician intimately familiar with all of your software systems and the Ministry requirements to make sure they are coherent. In practice, any adaptations to software should be made by its suppliers – the obligation to ensure this, however, is yours, so make sure you check for relevant updates.
Preparing for SAF-T
You need to check with your IT technicians on which of the programs used in the running of your business contain data which should be included in a standard audit file. Once this has been determined, contact the manufacturers of your software to check whether or not the programs support SAF-T formats – if not, and no update to change this is forthcoming, you may need to choose another software provider.
Sending off your SAF-T
SAF-T files such as JPK_VAT and others can only be sent in electronic form. Since tax books sent electronically should bear a secure electronic signature with a valid, qualified certificate, in order to transmit them you may use a free Trusted Profile or authenticate it once you have purchased a valid, certified electronic signature from one of the companies approved by the Polish government.
The Ministry of Finance regulates all issues concerning the method of electronic transmission of tax books; the regulations are available at their website.
There is a possibility of sending a SAF-T file by yourself, if you use the program provided by the Ministry of Finance.