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Standard Audit File for Tax
www.pwc.com
26.01.2016
PwC
Agenda
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1. Standard Audit File for Tax – basic issues
2. What hides inside the SAF-T structures?
3. How to adjust to the new requirements?
4. Doubts and questions about SAF-T
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Standard Audit File for Tax – basic issues
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Standard Audit File for Tax – basic issues
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The goal of introducing SAF-T is to improve and deepen the process of tax and treasury audit and to identify main areas of non-compliance in tax reporting.
SAF-T brought significant benefits to the tax authorities in countries in which thissolution has been already implemented. The biggest benefits were observed in such areas as:
• reduction of costs and duration of audit (ability to conduct audit remotely);• abnormalities specified on the whole sample – increased effectiveness;• ability to conduct audit of few taxes at once (eg. CIT-VAT comparision)
The idea of SAF-T works worldwide in two models – on demand and as compulsory, periodic data handling to the tax authorities.
Technologically SAF-T is based on a file in .xml form (according to OECD SAF-T 2.0 standard).
Taxpayers will send file to Ministry of Finance Gateway or, in case of big volumesof data, give it to the tax authorities on an external data storage medium (eg. DVD, pendrive).
Why?
How?
?? ??
??? ?
?
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Standard Audit File for Tax– basic issues
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Duty of generating SAF-T will apply to:
From 1.07.2016 ≥ 250 or > 50 mln EUR
From 1.07.2018 ≥ 9 or > 2 mln EUR
Reporting will concern taxpayer’s tax books.
Term „tax books” shall mean: accounting books, revenue and expense ledger, records and registers which must be kept by taxpayers on the legal basis for the taxpurposes
SAF-T was introduced with amendment to tax ordinance – new art. 193a
Who?
Legalbasis?
What?
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Standard Audit File fot Tax- What hides inside the SAF-T structures?
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Standard Audit File fot Tax– structures
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On 23.12.2015 test version of SAF-T appeared on the Ministry of Finance webstie. Test formulaof SAF-T consists of 7 structures:
Structure 1 – Accounting books
Structure 2 – Bank statements
Structure 3 – Warehouses
Structure 4 – VAT evidence
Structure 5 – VAT invoices
Structure 6 – Tax revenue and expenseledger
Structure 7 – Record of revenue
Typesof SAF-Tsections
Headline
Repeatable sectioncontainingdata concerningsystem provider,period
for whichthe file is prepared, etc.
Substantivepositions
Positions concerningvaluesfrom
tax booksand accountingevidences.
Control sums
All files contain controlvalues which are calculated as
a number of records and one or two values of
sum characteristic for each document
type.
PwC
Standard Audit File fot Tax– VAT evidence
VAT evidence structure containsinformation concerning transactionsincluded in records kept for the VAT purposes – not only data whichusually can be found in VAT registers.
Some doubts have risen about the following fields:
- Amount of non-taxable purchase
- Receipt of invoice date
- Invoice number
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Standard Audit File fot Tax– Warehouses structure
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Warehouses structure containsinformation concerning receipt, release and internal movementtransactions.
The structure requires very detaileddata, for example:
- unit price of goods / material,
- number of invoice or specificationconcerning received goods / material
Most sections of this structure, exceptfor headline, are not obligatory - itmeans that if a taxpayer did not havesuch type of transaction in a givenperiod, the field may be left unfilled.
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Standard Audit File fot Tax– VAT invoices structure
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This structure will be used to reporting information concerning sale invoices for a given period.
Doubts and questions concern:
- Data concerning vechicles mileageand number of workhours of newmeans of transport in case of intra-community supply of goods
- Lack of information concerningcorrective invoices and documentsequated with invoices
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Standard Audit File fot Tax– Bank statements structure
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This structure includes bank statements balances along with detailed records from taxpayer’saccounts.
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Standard Audit File fot Tax– Accounting books structure
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Accounting books structure includesinformation concerning mainly trialbalance and journal of general ledger.
Transactional data on single transactionlevel should be placed in this file. Transactional data should balance with accounts of the trial balance included in the file.
Doubts and questions concern such fieldsas:
- Transaction date and Evidence date
- Description of the transaction vs. desciption of the transaction on debit (credit) side
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Standard Audit File fot Tax- How to adjust to the new requirements?
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Standard Audit File fot Tax- How to adjust to the new requirements?
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IT systemsidentification
Creating list of systems and
data
Mapping Data testing
• Make list of systemsand assignSAF-T data to them.
• Test data in regard to their completeness and substantive correctnesson ready SAF-T.
• Identify systemsin regard to data contentfrom the perspective of individual structures.
• Build SAF-T reportingconcept.
• Decide if you willmodify system/systemsor use external solution.
• Prepare SAF-T fields to sy stem data mapping.
• Idenitify reports/ extracts which canbe used to acquirerequired data.
GeneratingSAF-T
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Doubts and questions concerning SAF-T
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Standard Audit File fot Tax– Doubts and questions concerning SAF-T
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26.01.2016
PwC
Standard Audit File fot Tax– Doubts and questions concerning SAF-T
Sample questions which may appear, concernin SAF-T introduction:
1. When can we expect final version of SAF-T structures?
2. Is MoF working on other/additional structures?
3. Can SAF-T structures change in time?
4. Will taxpayers be obliged to send data regarding transactions conducted before 01.07.2016 according to SAF-T regulations?
5. Are all fields within SAF-T obligatory?
6. What happens if part of data needed in SAF-T is outside of the system (eg. in Excel)?
7. How will SAF-T be handed to tax authorities?
8. How many times will the taxpayer have to present SAF-T files?
9. Should companies which belong to tax capital group but do not meet the definition of big enterprise generate SAF-T files?
10. Are SAF-T rules applicable to branch of foreign entity conducting activity in Poland?
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PwC
Contact
+48 502 184 961
PwC
+48 502 184 296
Marcin SidelnikDirector
Marcin MadejSenior Manager
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Thank You
© 2016 Pw C Polska Sp. z o.o.
