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STANDARD AUDIT FILE FOR TAX

From 1 July 2016, entrepreneurs who use computer software for financial and accounting records will be required to provide to the tax authorities data from the accounting books and accounting evidence (see the article What is accounting evidence) in the form of the so-called Standard Audit File for Tax (SAF-T ).  The data shall be provided at the request of the tax authorities.

Who is required to draw up SAF-T

Importantly, at first (from 1.07.2016) this obligation will apply to big companies (over 250 employees).  By the end of June 2018, smaller firms will be able to provide the data in the form of a standard audit file voluntarily.

Since July 2018 both small and medium-sized enterprises and micro enterprises will also have to provide at the request in the form of SAF-T all data, inter alia, of:  accounting books, bank statements, warehouse records, records of purchases and sales, VAT invoices and simplified records.  

Monthly, mandatory reporting of VAT records

The introduction of standard audit file resulted in  a new obligation.  Entrepreneurs who run their tax books in electronic form,  will be required to send on a monthly basis to the tax authorities the reports on the VAT records according to a given format (such as for SAF-T, more information below).  These records shall contain, inter alia:  the data necessary to identify the subject and tax basis, the amount of the tax due, the 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.

 

Importantly, these reports (for monthly periods), will have to be submitted by the 25th of each month without (as opposed to sending SAF-T, which will be held at the request of the tax authorities). This requirement will enter into force on 1 January 2017 for small and medium-sized enterprises and for micro enterprises a year later (in 1.01.2018).  Reporting of VAT records will be a separate activity independent from providing  SAF-T at the request of the tax authorities.

What is the Single Audit File?

The Standard Audit File for Tax is a collection of data (database), consisting of the information systems of entrepreneur, including information on business operations for the period in question, with layout and format allowing easy processing.  In other words, it is the standard by which the data is submitted to the tax authorities.  This data will need to be submitted to the Ministry of Finance in accordance with the template (in accordance with electronic format XML).  

What data will the single audit file contain?

Data to be submitted to the tax authorities in a single file will concern certain types of tax books and accounting evidence.  The Ministry of Finance has prepared a set of reporting formats and data required (the so-called structure) in areas such as:

  • 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

Data standards and formats of SAF-T also include details of receipts and reports from cash registers and records for the excise duty and currency exchange offices.  

For example, in the case of stock turnover, single audit file should include data such as:  the price of the goods, the unit of measurement, the value of the goods, the consignees of the goods, or invoice numbers.  The accounting and financial program should ensure coverage of precisely the information that will require the tax authorities in SAF-T.

Time limits

First, you need to establish when you will be required to send data (on request or automatically in case of VAT records).  The calendar is as follows:

Large companies (with more than 250 workers and 50 million euro of turnover).

  • From 1 July 2016 they transmit obligatorily at the request of the authorities data in the form of a single audit file.
  • From 1 July 2016 compulsorily and without being requested, send reports from the VAT records and in accordance with the structure of single audit file.

Small and medium-sized enterprises (with fewer than 250 employees, including foreign companies)

  • From 1 January 2017 compulsorily and without being so requested, they send monthly reports on VAT records (according to the established structure).
  • By 30 June 2018, send, on a voluntary basis, at the request of the tax authorities, data in the form of single audit file.
  • From 1 July 2018, mandatorily on request of the tax authorities send data in the form of single audit file.

Micro enterprise (less than 10 employees and EUR 2 million turnover)

  • From 1 January 2018 compulsorily and without being so requested, send monthly reports on VAT records (according to the established structure).
  • By 30 June 2018, send, on a voluntary basis, at the request of the tax authorities, data in the form of single audit file .
  • From 1 July 2018, mandatorily send on request of the tax authorities data in the form of single audit file

Attention!  If you want to determine precisely to which group of enterprises your business belongs to (large, small and medium, micro-enterprises), the exact definitions can be found in the Act on freedom of economic activity.

How to prepare

The introduction of a  for the financial and accounting software will require changes in the financial and accounting software of your business.  No matter whether this is accounting system or e.g. storage -  it must be able to ‘produce' Single audit file for tax authorities.  The file must be consistent with that of the Ministry of Finance.  Can I introduce changes on my own?  In theory, this is possible but it requires the IT technician who is thoroughly familiar with your financial and accounting systems and the one who can  ‘search' in your systems (invoice, warehouse) the data expected before the tax authorities concerned.  This data should be coherent with each other, even if they come from different systems.

In practice, adaptations to the software supplier will make jpk (keep in mind, however, that the obligation to adapt the system falls on you therefore check whether the company which supplied you the software had made a relevant update).

 

Preparation for standard audit file

  • Determine which programmes are applied in your business to accounting, record keeping, stock turnover.  Check with your IT technician whether they contain data which should include standard audit file (you will find the data in the files on the website of the Ministry of Finance).  Contact the manufacturer of the programmes and check whether the support of standard audit file is provided for.  If not, you may have to use the new software, operating standard audit file.

Sending standard audit file to the tax authority

The data will be transferred to the tax authorities by electronic means (in accordance with safety standards) or on a data carrier.  The tax books sent electronically should bear a secure electronic signature verified by way of a valid certificate.  Please note that the authority may require the reporting of data in a single file at any time in the course of checks, conduct a tax audit, tax or inspection proceedings.

Attention!  The issues concerning the method of sending data electronically and technical specifications for the storage media on which papers... may be recorded and transmitted, shall be laid down in a Regulation by the Minister of Finance.

Important!  If you want to send  on your own, you can use the program made available by the Ministry of Finance.  It allows for the preparation of data in a format for the VAT records ( jpk_vat) and sending them to the system of the Ministry of Finance.  More information and a detailed description of the of the programme can be found on the Ministry of Finance website.

If you have any problems or questions in connection with the single audit file you can send them to an e-mail to info.e-deklaracje@mf.gov.pl.

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