Standard Audit File for Tax for Poland (SAF-T)


Standard Audit File for Tax (SAF-T) was introduced with new change in the tax ordinance art. 193a
The taxpayers’ responsibility will be transferring, on request of tax authorities, tax books data in single accounting file.
Term „tax books” means: accounting books, revenue and expense ledger, records and registers which must be kept by taxpayers on the legal basis for the tax purposes.

VAT-registered taxpayers and foreign enterprises too.
The obligation to transmit data in the SAF-T format will also apply to companies registered for VAT in Poland, even if their fixed establishment is outside Poland.
Based on the explanations published on the official Ministry of Finance website, in determining whether a foreign enterprise is a large enterprise, all of its business activities have to be considered.
Also foreign enterprises that carry on business in Poland through a local branch will be required to disclose data in the SAF-T format at the request of the tax authorities.

SAF-T for large enterprises starting from 1 July 2016
From 1 July 2016 the obligation to use the SAF-T format will be imposed on enterprises that keep tax books using computer programs and classified as large, as defined by the Polish Freedom of Economic Activity Act: enterprises that at least in one of the last two financial years:

  • has employed more than 250 staff members (on an annual average);
  • or has achieved EUR 50 million in net turnover and the total assets in the balance sheet as of the end of one of those financial years exceeded a PLN equivalent of EUR 43 million.

SAF-T for micro-, small- and medium-sized enterprises starting from 1 July 2018
Between 1 July 2016 and 30 June 2018, micro, small and medium-sized enterprises will be able to choose whether they want to transmit their data during a tax inspection in the SAF-T format or not. Starting from 1 July 2018 will they be obliged by law to transmit „tax books” in the SAF-T format.

SAF-T standard
Till now, Standard Audit File for Tax was introduced in many UE countries, among others:

  • Austria,
  • France,
  • Luxembourg,
  • Portugal,
  • Czech Republic (VAT).

Technologically SAF-T is based on a file in .xml. The standard form was defined by the OECD (Organization for Economic Co-operation and Development).
The idea of SAF-T works worldwide in two models – on demand and as compulsory, periodic data handling to the tax authorities.
Taxpayers will send file to Ministry of Finance Gateway or, in case of big volumes of data, give it to the tax authorities on an external data storage medium (eg. DVD, pendrive).

SAF-T structures
On 23 December 2015 test version of SAF-T appeared on the Ministry of Finance website in order to make them available to the public consultation.
On 9 March 2016 Ministry of Finance published on its website the final logical tax books structure and accounting documents constituting the SAF-T in Poland:

  • JPK_KR – Księgi Rachunkowe (Accounting books)
  • JPK_WB – Wyciągi bankowe (Bank statements)
  • JPK_MAG – Magazyn (Warehouse/Storage)
  • JPK_VAT – Ewidencje zakupu i sprzedaży VAT (VAT evidence)
  • JPK_FA – Faktury VAT (VAT invoices)
  • JPK_PKPIR – Podatkowa księga przychodów i rozchodów (Revenue and expense tax books)
  • JPK_EWP – Ewidencja przychodów (Revenues registry)

And more structures are planned (for example Fixed Assets, Intangible assets, Excise, Fiscal receipt…)

Types of SAF-T sections:

  • Headline
    Repeatable section containing data concerning period for which the file is prepared, etc.
  • Company
    Repeatable section containing company data: name, address, VAT identification number
  • Header positions and detailed lines
    Positions concerning values from tax books and accounting evidences.
  • Control sums
    All files contain control values which are calculated as a number of records and one or two values of sum characteristic for each document type.

SAF-T and Value Added Tax

Further changes to the Tax Act and the Value Added Tax Act were introduced very quickly in the last moment.
On 7 June 2016, the President signed the act of 13 May 2016 amending the Tax Act and certain other acts. The Act was published in the official Journal of Laws on 14 June 2016.
The new legislation obligates the VAT-registered taxpayers (except those exempt from VAT) to keep computerized records of all data required to fill out tax form VAT-7. Taxpayers will be further obliged to transmit details of VAT records as a SAF-T without any additional request from the tax authorities.

The data will have to be filed monthly by the 25th day of the next month.
Large enterprises will have to start filling JPK_VAT structure starting from 1 July 2016.
Small and medium-sized enterprises will have to start filing VAT data in the SAF-T starting from 1 January 2017.
The obligation will reach micro enterprises since the beginning of 2018.

Consequences & Legal Penalty
Enterprises which, for no good reason, refuse or fail to present tax ledgers or accounting evidence underlying those ledgers in the SAF-T format within a specified time frame will be liable to a fine of 2 800 PLN.

Anyone who attempts to thwart or impede the tax authorities’ procedures, including especially failure to present tax ledgers, or accounting evidence underlying those ledgers, in the SAF-T format will be liable to a fine from 617 PLN up to 17 769 600 PLN.

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