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The presentation will begin shortly, thank you for waiting Stay informed with Deloitte Global tax app Stay up to date with the international tax news by downloading the tax@hand app Deloitte Belgium app Receive Belgian tax news, register for Deloitte Academy events, access industry highlights and many other reports and tools Tax news by Deloitte Belgium Follow us on LinkedIn to stay informed of upcoming Deloitte Belgium Tax seminars and webinars, and follow the latest Belgian tax developments © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 1
Headline Verdana Bold Deloitte Academy Seminar From e-Audit files upon demand to real-time reporting. Are you ready for SAF-T? Deloitte Belastingconsulenten/Conseils Fiscaux
Agenda Topic Content Presenter Timing Welcome & Registration (sandwich lunch) Introduction Global Trend on Tax Transparency, audit and data Frederik 13:00 p.m. – 13:15 p.m. Current evolutions in EMEA From e-Audit to Real-Time Reporting Pieter 13:15 p.m. – 13:45 p.m. Addressing the Challenges Technology, Process and Data Pieter 13:45 p.m. – 14:00 p.m. Break Process Support Solution Approach Pieter 14:15 p.m. – 14:45 p.m. Demo (Disruptive) Technology Update Sample Case: Blockchain Frederik 14:45 p.m. – 15:15 p.m. Final Conclusions Conclusion and next steps Liesbet 15:15 p.m. – 15:30 p.m. © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 4
Introduction Setting the scene A variety of forces are combining to change the world of compliance: financial pressure on governments to focus on tax take public focus on transparency from corporate taxpayers This has resulted in a variety of new laws and efforts at national and international level Tax environment now focussed on transparency and data © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 6
Digital Tax is growing fast (some examples) Countries worldwide are adopting new ways of monitoring, many of these are Digital: Digital Tax Policy Legal initiatives e.g. Country-by- VAT rules in digital economy Country Reporting (Global) e-Commerce and MOSS OECD Countries Cross-Border collaboration, Electronic disclosure of VAT Ledgers information sharing and joint audits. Poland Czech Republic Legal disclosure and approval (local) Netherlands: Horizontal Monitoring Electronic Audits and SAF-T UK: SAO Norway Lithuania: iSAP Germany: GDPdU Electronic invoice disclosure and Poland: JPK required e-invoicing France: FEC Belgium: B2G Luxembourg: FAIA France: B2G … Italy: B2G Spain: SII Modernization of tax authorities and Brazil: SPED audit procedures. China: Golden Tax System UK: Making tax Digital © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 7
Digital Tax is growing fast Different ways of Electronic Audits Next: Blockchain ? • Digital technologies Standardized allow for more data to Electronic become available. Transactions • The level of detail and and Ledgers the variety of data is Standardized increasing. Electronic Distributed/Shared audit files • Authorities explore use Data of sophisticated, and Electronic audit files Immutable Records cognitive technologies to Structured Format and audit trail. use tax data. OECD SAF-T Structured Format Elements • End-to-end transparency Detailed line level is anticipated with the OECD SAF-T Ad hoc Format Elements introduction of new disruptive technologies such as Blockchain. Upon Request Upon Request Periodic and (Near) Real-Time Data Frequency and Format © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 8
eAudit upon demand Example: Belgium Data Requested Lead Time Typical Activities SAP ERP Tables for FY2016 1 month for data extraction Classic audit support • Financial/Tax Posting +1 month, after additional information Analyze and reconcile data, find requested from the inspector underlying documents and off • Master Data system information Customers/Suppliers Prepare for questions and responses Accounts/Cost centers Tax codes © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 10
SAF-T upon demand Example: France Data Requested Lead Time Typical Activities Fichier d’Écriture Comptable (FEC) On-site: 1st meeting Assistance on the preparation (format) and testing of the FEC file (content) Off-site: 15 working days Pro-active validations In advance © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 11
SAF-T Periodical Example: Poland Data Requested Lead Time Typical Activities JPK_VAT - VAT sales & purchase Monthly Assistance in the preparation and filing of register the reporting Embedded in compliance process Challenge : link with compliance process (to reconcile) + shorter lead-time © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 12
Real-time reporting Example: Brazil Data Requested Lead Time Typical Activities Sales invoices Real-time Set up of the process Embedded in the sales and supply chain process Involvement in IT infrastructures © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 13
Real-time reporting Brazil: Invoice Flow 3 2 4 1 © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 14
SAF-T: Introduction © 2016 Deloitte Belgium Deloitte Academy Seminar – SAF-T 15
SAF-T: Introduction Europe: Standard Audit File for Tax (SAF-T) SAF-T has been designed to capture data from a number of areas found in a typical business accounting system Periodically per legal entity General ledger • Journals Accounts Payable • Supplier master data Master data • Invoices • Payments Trans- Accounts Receivable action • Customer master data • Invoices Balances • Payments • Fixed assets Asset Master Files • Depreciation and revaluation Across taxes, including info Inventory relating to • Product master data • VAT • Movements • CIT • Transfer pricing © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 16
The move towards Electronic Audits The changing face of tax compliance From taxpayers’ information systems to authorities’ audit software Yesterday Today • Manual keying of data • Automatic or semi automatic keying of data • Slow and uncertain transmission of returns • Automatic production of reporting documents • Risk of loss of documents and penalties • Some e-filing/cross checking of information Need to • Sample-based approach for audits • Direct audits of ERP systems/ update accounting software IT systems Tomorrow Today • (already today?) • Safe transmission of data Production of • New form of automatic controls • Automatic consistency checks compliant performed standard data • In theory faster, surer, more precise, more efficient • Incontestable proof of filing • Issue: Need for standardized • General lack of consistency documents for taxpayers’ IT systems in testing/filing of data • Death of the tax return? • Slight country variations in format and requirements © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 17
SAF-T: upon request © 2016 Deloitte Belgium Deloitte Academy Seminar – SAF-T 18
SAF-T: upon request Country Legal ent. Non-est. VAT reg. Comments Austria France All VAT registered companies and branches. Germany Lithuania Exceptions: - Taxpayers exempt from Standard Chart of Accounts ("PCN") obligation Luxemburg - Taxpayers subject to the simplified VAT return regime - Taxable turnover whose annual turnover is below 120.000,00 EUR - Small taxpayers with few transactions (+-500) so that manual check is easier than submission of an electronic file. © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 19
SAF-T: upon request Country Legal ent. Non-est. VAT reg. Comments Netherlands All companies currently liable to maintain book-keeping information electronically. Exceptions: (1) Companies with VOES registrations in Norway Norway (2) Companies with turnover of less than 5 Million NOK (3) Companies with less than 600 vouchers a year Companies liable to keep books that are covered by the exceptions (2) and (3), but have bookkeeping information available “electronically”, are still covered by the SAFT requirement. -JPK_KR (Accounting books) -JPK_WB (Bank account statement) -JPK_MAG (Warehouse) Poland -JPK_FA (Invoices) -JPK_PKPIR (Revenue and expense ledger) -JPK_EWP (Revenue registry) Portugal Companies subject to Corporate Income Tax © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 20
SAF-T: periodical © 2016 Deloitte Belgium Deloitte Academy Seminar – SAF-T 21
SAF-T periodical Country Legal ent. Non-est. VAT reg. Comments Czech Republic VAT Control Statement i.SAF : VAT records Lithuania i.VAZ, data relating to goods consignment/transport Portugal Companies subject to Corporate Income Tax Poland JPK_VAT, VAT sales and purchase register Slovakia VAT Control Statement © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 22
Real-time reporting © 2016 Deloitte Belgium Deloitte Academy Seminar – SAF-T 23
Real-time reporting Country Requirement Legal ent. Non-est. VAT reg. Comments Law has been declared unconstitutional because the Electronic reporting for all France sales with VAT fine for non-compliance was considered disproportionate. Businesses will receive in return from the tax authorities a unique invoice number that they must include on the invoice prior to issuance to their Electronic reporting of all B2B customers. sales invoices with VAT above Hungary HUF100,000. (From 1 July The maximum fine for failing to comply with the new 2018) rules will be up to HUF500,000 per invoice. No other details yet. Daily reporting of JPK_WB early stage / an idea to cross check payments with (Bank account statement) Poland (From 1 Sept 2017) supplies. Lots of resistance from business and financial sector, so it is uncertain if it will go ahead SII – Suministro Inmediato de Información Electronic reporting for all Spain sales with VAT (From 1 July 4 day timeframe as of the moment they issue or 2017) receive them (deadline extended to 8 working days between July 1st, and December 31st 2017) © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 24
Spain – Suministro Immediato de Informacion Real-time reporting requirements • The requirement is to submit invoice records, plus certain additional information, not the invoices themselves • The regulations apply to large businesses (€6M turnover), those in a refund regime and VAT groups. Taxpayers can also optionally adopt • The introduction of the SII regime removes the requirement to submit the monthly, quarterly and annual informative declarations returns (the Modelo 347, 340 and 390), not the VAT returns themselves that would still need to be filed • The regulations apply to both invoices issued and invoices received. Different XMLs for invoices issued/received, capital goods, Intra-EU movements; payments in cash The timing of submission is eight days after issuance for 2017, and reduces to four days in 2018 • For AR, this is from invoice issuance date • For AP, this is from the date the invoice is accounted • The tax authority will have a web portal for manual submission, where there are minimal transactions • There will be a web service, which can integrate larger volume of invoice records – this could be “bolted on” to the ERP, or used as an XML import tool (either manually or through third parties) • There will be some cross-validation of data by the Tax Authority of the invoice records © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 25
Spain – Suministro Immediato de Informacion Compliance impacts • Submission contents − Content of filings is not the same as the current purchase books – new reports will be required − Submission deadlines (tending to daily filings) − Descriptions are not standardized, but should not conflict with the VAT rate provided − Recoverable tax amount reported for each invoice – partial exemption adjustments? Impact to other Special Schemes (TOMS)? − Employee reimbursements – report against employee or underlying supplier? • Retroactive reporting solution required − The regulation is effective from 1 July 2017 – but also note that during July – December 2017, there is a requirement to retroactively submit all invoice records from 1 January 2017 to 30 June 2017 • Non-ERP based transactions (e.g., intercompany invoices, retail systems, etc.) – how do these consolidate into the SII submission? • Timing of reporting of transactions, submission deadlines (daily submissions) • Submission and audit processes ERP data Consolidate and Web Tax Authority Audit process validate portal database data External data © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 26
Spain – Suministro Immediato de Informacion Key items New obligations on transactions Dates of implementation recording • Entry intro force by 1 July 2017. • The new Anticipated Electronic VAT Reporting System (SII) entails the However, the VAT ledgers covering the first electronic supply, through the Spanish half of 2017 must be submitted before 1 Tax Authorities on-line platform, of January 2018 billing registries which are part of the VAT ledgers • Mandatory for large entities, VAT grouping, and companies included in the Monthly VAT Deadline to submit the information Refund Registry -REDEME- (62.000 taxpayers more or less = 80% of VAT • Issued invoices: Four days from its issuance. Key revenues in Spain) If its issued by the recipient or a third party, eight days. Anyway, always before the 16th day issues • Optional for taxpayers who voluntarily want of the following month from the accrual date to enroll the system, by submitting the • Received invoices: Four days from its accounting. corresponding census form Always, before the 16th day of the following month from the accrual date • Imports: Four days from the date in which the accounting document (in which the VAT quota is indicated) was registered. Always, before the Ways of submission 16th of the following month from the accrual date • On-going basis through a “web service” • Saturdays, Sundays and national holidays are from the Spanish Tax Authorities on-line excluded from counting platform • Temporary period: (1 July – 31 December 2017) deadline is extended from four to eight days • Taxpayers with few operations could report the information through a “web form” • Billing by a third party: Eight days © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 27
Challenges © 2016 Deloitte Belgium Deloitte Academy Seminar – SAF-T 28
Challenges Challenges driven by the tax authority • Short implementation time • Requirements not/limited available in local language • Tax inspector cannot bring clarity/lack of experience Challenges driven by the company Process • Indirect – direct – statutory accounting process − Local COA − Out of book adjustments − Opening balance/closing balance bookings • Reconcile with compliance process © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 29
Challenges Technology • ERP landscape • Underlying sub systems • How to extract • How to validate • How to generate compliant files • How to communicate towards tax authorities Data • Which data to extract • Where to extract from • Master Data completeness • How to reformat data / fixed values © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 30
Break © 2016 Deloitte Belgium Deloitte Academy Seminar – SAF-T 31
eAudit: different ways to get prepared © 2016 Deloitte Belgium Deloitte Academy Seminar – SAF-T 32
eAudit: upon demand or periodical Country-by-country or a strategy Spain Spain Portugal Belgium Poland Portugal Poland © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 33
Country-by-country Country specific Data Model Spain Per jurisdiction, the specific data model is linked to the e-process Knowledge Country data models often E-requirements per country: captures info from What can be requested/when Portugal General Ledger Poland Indirect vs direct tax Accounts Receivable Penalties for non compliance Accounts Payable Overview of data fields Fixed Assets Overview of data format Inventory Matching with overall structured data model eAudit Process © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 34
Strategic approach Spain Overall Corporate Data Model Structured data model is based on Knowledge the OECD SAF-T model. Data model captures info from Portugal General Ledger E-requirements per country: Accounts Receivable What can be requested/when Poland Accounts Payable Indirect vs direct tax Belgium Fixed Assets Penalties for non compliance Inventory Overview of data fields Overview of data format Matching with overall structured data model eAudit Process 1 time analyze phase Applicable to countries where no SAF-T is yet in place Prepared for change upfront Risk & opportunity drivers can be applied © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 35
eAudit: Dashboard Demo © 2016 Deloitte Belgium Deloitte Academy Seminar – SAF-T 36
Real-time reporting process Example for Spain 3. SII XML file ERP SII convertor/ Communication Spanish Tax generator platform Administration 4. SII XML response 1. Raw SII SII Communication Data process & error handling FTP Server © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 37
Technology Update © 2016 Deloitte Belgium Deloitte Academy Seminar – SAF-T 38
Exponential technologies Tax Analytics Implications • Exponential technology is already disrupting the work of tax professionals • At simplest level automation reduces the amount of mundane/repetitive task • Exponential technologies contribute to an increase in the availability of data, which in turn drive more sophisticated analytic approaches • Cognitive technologies can help analyse legislation, or help extract/categorise tax data from underlying sources • Scope for cognitive and analytics technologies to interact provides valuable predictive knowledge searches on tax technical issues © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 39
Connected world Overview • Interoperability of services and data is ever more important in the tax world • Both tax authorities and commercial enterprises are embracing APIs (application programming interfaces) to better serve clients • We are now seeing the advent of ‘Digital Government’ where interfaces enable data exchange in support of various government services • There is future potential for corporate to leverage APIs as well as explore Blockchain as a means to maintain and demonstrate the reliability of shared data © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 40
Blockchain as a system More than crypto-currencies, Blockchains have multiple applications As a Currency As a System Systems’ native currencies (e.g., Bitcoin, XRP) Systems’ network (e.g., Blockchain, the Ripple Network) • Measures the market value of goods and services Blockchain • Enables efficient transfer of value and information System • Immutability of the system guarantees high-fidelity • Intermediates the exchange of goods and services • Can be reliably saved and retrieved as store of value • Allows for programmability Each application serves Examples as the foundation for Smart Contracts more sophisticated uses • Digital cheques / IOUs Program protocols to execute transactions when a set of pre-determined conditions are • Automatic financial instruments met • Parametric insurance contracts • Automated market making Transfer of Value Enable low-cost, near real-time value transfer without an • Domestic and international remittance intermediary • Internal payments settlement Expand to transfer of other assets beyond “money” • Clearing and settlement of securities • Exchange of low liquidity assets Record Keeping Create an immutable record without reliance on a trusted third party • Digital certificate of ownership for physical assets Improve efficiency of record keeping via automation • Transaction validation of digital assets • Financial accounts Greater sophistication © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 41
Vat automation in the Digital Supply Chain Example for Physical Supply of Goods Example – High Level overview of a system using electronic messaging with shipment approval and confirmation Approval Approval Code e-Invoice Paper Invoice © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 42
VAT and Blockchain 1. Each transaction consists of one Possible Blockchain applications? block. 2. Mutual agreement on content of the block. 3. Each Block is added to the chain to form a distributed ledger. 20 Message VAT N° Taxable amount and VAT Description good/service Etc. 20 Blockchain Bank transfer 120 © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 43
Some Design thinking to your ERP How to prepare ERP systems will continue to remain a backbone solution, driven by a legacy of master data and process standardization. However needs connectivity and integration with a growing eco-system of applications both internal and external Faster: From ad-hoc to monthly and real-time. Invoice and Document Management. Immediate response required! Integration management. Better: Eliminate error prone process and manual interventions Tax Reporting and Automation Tax sensitive process should be touchless Data and Process Analytics. Controlled: Measure and Monitor change and deviations Business Process and Activity monitoring. Full transparency Process orchestration, full end-to-end integration No Mistakes allowed. © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 44
Final Conclusions © 2016 Deloitte Belgium Deloitte Academy Seminar – SAF-T 45
Final Conclusions Key Messages Tax authorities are going Digital in a response to combat fraud and to increase fairness and efficiency in revenue collections. SAF-T is one example but you need to respond fast. Technology is the tool, Data is the Fuel The availability of digital tax data is not determined by the existence of a predefined format. It is a business process produce and an ERP system’s legacy. Tax, Business and IT Alignment It assumes alignment, formalization and standardization in business processes far beyond your tax function. © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 46
Final Conclusions Next Steps 1 Get a view on your process and data quality Where are the gaps? 2 Get connected. take the lead and ensure external regulatory requirements are in line and with the internal organization. This includes the business and IT. © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 47
Contact Information Liesbet Nevelsteen Pieter Van Dyck Frederik Drappier Partner, Senior Manager, Senior Manager, Indirect Tax Tax Management Consulting Indirect Tax lnevelsteen@deloitte.com pivandyck@deloitte.com fdrappier@deloitte.com Work : +32 2 600 66 53 Work: +32 2 800 25 65 Work: +32 2 749 54 77 Mobile : +32 496 57 48 79 Mobile: +32 497 53 29 73 Mobile: + 32 496 26 16 64 © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 48
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Annex © 2016 Deloitte Belgium Deloitte Academy Seminar – SAF-T 50
eAudit Process © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 51
Aanalysis Analysis of the technical Set up & Processes • Review of the current compliance processes • Statutory process • Direct tax process • Indirect tax process • Review significant Business event for the period • Review Accounting systems landscape • Review tax audit history • Define country by country approach or structured data model © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 52
Data Extraction Extract the tax relevant data from the different source systems identified during the analysis • Which date should be extracted depends on whether are structured date model is put in place or a country by country approach is implemented • Based on the outcome of the analysis, different data might need to be extracted from different source systems (main ERP, legacy systems, billing systems ….) • Extracted data should be transferred to a data platform (data warehouse / data mining tool) for further handling in the next phases. SAP DART TJC SNI SAP OSS Notes Data Warehouse … © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 53
Data Validation Extracted data should be validated prior to the assembly of the eAudit file Records Transactions Data Mining Master Data Lines Tools: Company Code Vendors/Customers – Caseware IDEA Fiscal Year Tax Codes – ACL Analytics Customized Data Warehouse Queries … © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 54
Data Reconciliation The extracted data should reconcile official filings Automated Not Automated: Sample testing Criteria: - Fiscal Year - Business Events - Size - Etc. © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 55
Assembly Assemble the extracted data into an eAudit file according to the local requirements • Different file formats (csv, xml,…) • Per jurisdiction the file structure varies • Local required default values can be expected • e.g. Portugal – movement type = • GR = Delivery note TJC • GT = Transport guide SNI • GA = Transport document for own fixed assets SAP OSS Notes • GC = Consignment note Data warehouse queries • GD = Return note Data Mining Tools: – Caseware IDEA – ACL Analytics © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 56
Process Real-time vs upon demand/periodical • The same process applies but in real time reporting there are additional challenges • Less preparation time • No manual intervention • eAudit process should be linked as close as possible to where the correct data is stored • Automated communication protocol/platform • End-to-end automated processes © 2017 Deloitte Belgium Deloitte Academy Seminar – SAF-T 57
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