Standard Audit File: changes in the file structure

The law on tax on goods and services undergoes continuous changes. Only a few months after the entry into force of the provisions concerning the SAF, the first alteration of the VAT SAF structure appeared. This means that large companies, which had devoted a couple of months to prepare the report, will have to adapt to the new modifications, while small and medium-sized enterprises will send entire reports in the altered version.

VAT SAF

The structure update covers several areas. The blueprint has been extended by adding new fields, while other fields but changed their chargeability. The alteration will be effective as of January 2017.

In the Sales part, field K_39 was added to display of the amount of tax on intra-Community acquisition of motor fuel, subject to payment on dates referred to in Article 103 paragraph 5a and 5b of the Act. Fields containing contractor data – name and address – have now become mandatory.

On the Purchase side, a box for the date of purchase appeared. It is mandatory for all entries in the report. Another new field is K_50 for displaying values of adjustments of input tax referred to in Article 89b paragraph 4 of the Act.

Header

There was also a change in the layout of fields in the header of the report. The REGON (National Business Registry Number) fields are not mandatory. This is in response to the numerous submissions of foreign companies, obliged to report in the SAF format, but unable not present the REGON symbol.

According to the declaration of the Ministry, the structure of the header is to be updated for other parts, too.

Amendments and adjustments to VAT SAF

Correcting the VAT return is a standard activity, often performed by companies. Different transactions are due for VAT purposes at different periods of time and under different conditions, hence there is need to change the declaration.

According to the initial assumptions, VAT SAF adjustments were to be marked by changes in the value of the CelZlozenia (Purpose of Submission) parameter in the file header. At the initial stage of the structure, the announced solution was not supported – the electronic gate on the Ministry’s side did not accept files marked as adjustments. What it meant in practice was that when the need to make an adjustment to VAT SAF transpired, the company had to send another file covering the same time span, but with altered data. The Ministry accepted the file sent at the latest date as final. That approach had certain consequences: at the initial stage the company had difficulties with procurement of a complete file and used to send several smaller files for a single accounting period which, taken together, were supposed to form the entire declaration. The logic accepted of the Ministry took into account only the last sent report.

At present, with the introduction of the new structure, a functionality covering the reception of VAT return adjustment is to be made available by the Ministry. In consequence, the recipient of the report will be able to distinguish between the original version and the adjusted report which may include corrections.

The Apollogic SAF application fully supports the dispatch of both periodic SAF reports and report adjustments. It includes archiving files, an option to view and validate the correctness of introduced values.