2021 Standard Audit File - Tax (SAF-T) - NOA Tax Advisors NOA Group 8/17/2021
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2021
Standard Audit File – Tax (SAF-T)
NOA Tax Advisors
NOA Group
8/17/2021
Standard Audit File - Tax (SAF-T)
Voluntary testing for submission of informative
statement D406T
Amendments presented in brief:
Given that January 1, 2022, is the first deadline for submission of the Standard Audit File –
Tax (SAF-T) for large taxpayers, the National Agency for Fiscal Administration has started
since the beginning of 2021 the publication of information regarding the Standard Audit
File – Tax (SAF-T).
Thus, on August 9, 2021, on the Decisional Transparency section of the ANAF website, a
project was published updating the SAF-T technical documentation.
Within this project, the following documents were published:
• SAF-T Validator Mode.
• Test files for the SAF-T Validator;
• SAF-T schema, version 4.11;
• XSD schema for SoftJ, version 2.3;
• Electronic form D406T “Model – SAF-T report pdf with xml attached – valid data –
values from the VAT nomenclature”;
• Instructions for the Validator Mode (DUKValidator) for taxpayers;
• Taxpayer’s Guidance for preparing and submitting Information Return D406
Standard Audit File – Tax (SAF-T), version 2.0.
1
Bucharest, 1st District +40 771 590 129
4 Pipera Road, 4th floor www.noagroup.ro
Table of contents
What is SAF-T? ................................................................................................2
What information is transmitted via SAF-T? ...............................3
Who has the obligation to submit the Informative
Statement D406? ......................................................................................... 4
Deadlines for submitting the first Standard Audit File –
Tax .......................................................................................................................... 4
SAF-T reporting method .................................................................................................................................................... 5
What does voluntary testing entail? .......................................................................................................................... 7
Amendments explained in more details:
Key words: What is SAF-T?
❖ The Standard Audit File – Tax (SAF-T) is an international standard
• The Standard designed by the Organization for Economic Cooperation and
Audit File – Tax Development, for the electronic exchange of accounting data
(SAF-T) between taxpayers and national agencies of tax administration.
❖ The Standard Audit File – Tax (SAF-T) is an electronic file, based
on XML, internationally standardized for the transmission of tax
reports, VAT reporting from the taxpayer to the tax authorities.
Basically, SAF-T is a file that contains accounting data
automatically extracted from taxpayers’ accounting systems,
• Informative
Statement which are exported and stored in a standardized format.
D406
❖ Through SAF-T, the National Agency for Fiscal Administration
(NAFA) will be able to perform some electronic checks, without
having to perform fiscal controls or inspections at the taxpayer’s
premises.
❖ The implementation of this standard presupposes the obligation
of the taxpayer to provide to the central fiscal body a statement
containing information from the fiscal and accounting records,
respectively the Informative Statement D406.
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Bucharest, 1st District +40 771 590 129
4 Pipera Road, 4th floor www.noagroup.ro
Key words: What information is transmitted via SAF-T?
• Header
❖ Header – general information about the file, the name of the
software that generated it, the name of the company that
submitted SAF-T.
❖ Master Files – this section contains subsections for more
information such as:
• Master Files ➢ General Ledger Accounts
➢ Customers (identification data, analytical account, initial
and finale balance debtor/creditor);
➢ Suppliers (identification data, analytical account, initial
and finale balance debtor/creditor);
➢ Tax Table (specific tax information);
➢ OUM Table;
➢ Analysis Type Table (information on the structure of the
taxpayer’s cost centres).
➢ Movement Type Table;
➢ Products;
➢ Physical Stock;
➢ Owners (details regarding stock owners);
➢ Assets.
• General
Ledger Entries
❖ General Ledger Entries – information on accounting records, at
transaction level, including analytical accounting accounts.
❖ Source Documents – information about source documents such
as:
• Source
documents ➢ Sales invoices;
➢ Purchase invoices;
➢ Payments;
➢ Movements of goods;
➢ Asset Transactions.
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Bucharest, 1st District +40 771 590 129
4 Pipera Road, 4th floor www.noagroup.ro
Key words: Who has the obligation to submit the Informative
Statement D406?
• Double entry ❖ The obligation to submit the Informative Statement D406
accounting belongs to all Romanian legal entities and to the Romanian units
without legal personality of foreign legal entities, which have the
obligation to keep double entry accounting.
❖ Below we list some of the legal persons or units without legal
personality that have the obligation to report SAF-T:
➢ Joint-stock companies;
➢ Limited partnership with a share capital;
➢ Limited partnership by shares;
➢ Partnerships;
• Categories of
taxpayers ➢ Limited liability companies;
➢ Other legal entities;
➢ Units without legal personality in Romania that belong to
legal entities established abroad;
➢ Foreign legal entities that carry out activity through a
permanent establishment in Romania;
➢ Foreign legal entities that have the place of effective
management in Romania;
➢ Profit or non-profit making associations;
➢ Non- resident companies that have a registration code for
VAT purpose in Romania.
Key words: Deadlines for submitting the first Standard Audit File –
Tax
• Monthly or ❖ The submission of the Informative Statement D406 will be made
quarterly monthly or quarterly, depending on the fiscal period for VAT, and
submission
in case of those who do not have a VAT code, the reporting will be
done quarterly.
❖ Depending on the category of taxpayers, the following
submission deadlines (reference dates) of the first Informative
Statement D406 have been established as follows:
➢ Large Taxpayers – starting with January 1st, 2022;
• January 1, 2022
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Bucharest, 1st District +40 771 590 129
4 Pipera Road, 4th floor www.noagroup.ro
• Year 2022 ➢ Medium taxpayers – since 2022, but no effective date has
been published yet;
• Year 2023 ➢ Small taxpayers – starting with 2023;
➢ Newly registered taxpayers after the reference date for
each category – from the actual date of registration.
Key words: SAF-T reporting method
• The last
calendar day of ❖ The informative Statement D406 will be submitted in electronic
the month format, as follows:
following the
reporting ➢ Until the last calendar day of the month following the
period reporting period (month/quarter), for information other
than Inventories and Assets;
• Date of
submission of ➢ Until the deadline for submitting the financial statements
financial for the financial year, for Assets;
statements
➢ Upon request from NAFA, within the term established by
the fiscal bodies, which may not be less than 30 calendar
• 30 calendar
days from the date of the request, for Inventories.
days
❖ Grace period: taxpayers will be granted a grace period of
3 (three) months for the first reporting, from the date when the
• Grace period
submission obligation becomes effective for that taxpayer,
period during which failure to submit or the incorrect/
• Qualified incomplete submission will not be sanctioned. However, the file
digital
must be submitted also for that period at the expiration of the
signature
3-months of grace.
❖ For submission of form D406, the taxpayer who has the
submission obligation, will have to download and fill-in the form
and to sign it with the digital signature certificate enrolled at
NAFA for submitting tax documents and forms in electronic
format.
❖ In order to prepare the form D406, taxpayers can use several
methods to generate the XML file that will be attached to the
statement, such as:
➢ Automatic generation of a file in XML format through
• Generate file in internal software – for taxpayers who use accounting
XML format computer systems or ERP systems;
➢ Preparation with an XML editor of the statement by
editing on the SAF-T scheme with the direct
introduction of the relevant data – for taxpayers who do
NOT have computer accounting systems or ERP systems;
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Bucharest, 1st District +40 771 590 129
4 Pipera Road, 4th floor www.noagroup.ro
➢ External generation of a file in XML format by
processing by a data operator specialized on
e-reporting/ e-filling, with the data operator’s software
– for taxpayers who use outsourced financial – accounting
services.
❖ The preparation and submission of the Informative Statement
D406 involves the following activities:
➢ Generation of the XML file in SAF-T format by the
taxpayer’s own computer system;
• Preparation
and ➢ Verification of the structure of the XML file and of some
submission of correlations between data through the validation
Informative informative program to be provided by ANAF;
Statement
D406 ➢ Generation of the Informative Statement D406 as an
electronic document in PDF format with XML attached
and electronically signed with the qualified digital
signature of the taxpayer;
➢ Obtaining the proof of submission with the results of the
processing of the informative statement and the standard
SAF-T file attached;
➢ Re-submission of the forms with the corrected SAF-T file,
if NAFA has identified errors contained in the proof of
submission.
➢ Keeping a proof of the content sent to NAFA.
❖ In order to report the data, a series of nomenclatures available in
Romania will be used. These nomenclatures fall into the following
categories:
➢ Nomenclature for taxes categories and tax codes – details
how the taxpayer must complete the TaxType and
TaxCode fields;
➢ Nomenclatures of stock movements coding;
➢ Nomenclature of assets movements coding;
Nomenclature
➢ Nomenclature for units of measurement;
➢ Nomenclature for countries, counties – details the types of
coding for bank accounts according to ISO 13616;
➢ Nomenclature for chart of accounts, divided as follows:
• Nomenclature of accounts plans for companies;
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Bucharest, 1st District +40 771 590 129
4 Pipera Road, 4th floor www.noagroup.ro
• Nomenclature of the Chart of Accounts applicable to
credit institutions and non-banking financial
institutions;
• Nomenclature of accounts plans for insurance
companies.
➢ Nomenclature for coding the types of payments, divided
as follows:
• Nomenclature Types of invoices issued and received;
• Nomenclature Payment / collection mechanism?
Key words: What does voluntary testing entail?
❖ Voluntary testing represent a form of assistance through which
• Voluntary any taxpayer can test their Informative Statement D406T, which
testing also includes the XML file in SAF-T format, generated by their own
systems from a semantic and syntactic point of view.
❖ The voluntary testing of the Informative Statement D406T was
announced to start on August 16, 2021.
• August 16, 2021
❖ During the voluntary testing, the preparation of the Informative
Statement D406T shall be done with the same Soft-J program
provided by NAFA, by following the instructions for the
submission of the Informative Statement D406.
❖ D406T forms, SAF-T files and the information transmitted
through them are not processed, stored, used as tax information
• Informative and are not used for further risk analysis by NAFA.
Statement
D406T
❖ Submission and validation of D406T test statements can be done
by taxpayers who prepare / test their IT systems for the
preparation and submission of the D406 informative statement
and by IT solution developers – for their customers. Submission
and validation of D406T could be made any time after the start
date of voluntary testing program, with no time limit.
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Bucharest, 1st District +40 771 590 129
4 Pipera Road, 4th floor www.noagroup.roHow we may help you:
The NOA Tax Advisors team supports companies by providing advice and guidance
in various cases on the new legislative changes as mentioned above, as well as in
all situations encountered from a tax point of view.
The NOA Tax Advisors team is at your disposal for more details regarding those
presented in this legislative news summary.
Best regards,
NOA Team
Otilia Pețu Mircea Dumitrașcu Lidia Terzea Maria Pascu
Managing Partner Partner Associate Director Senior Tax Manager
otilia.petu@noagroup.ro mircea.dumitrascu@noagroup.ro lidia.terzea@noagroup.ro maria.pascu@noagroup.ro
„It’s not just about the nicely packed advices, we’ve added the practical, the tailored and the client experience.”
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