Are You Ready for Romania SAF-T? Known as D406

2021

Romania SAF-T known as the D406

The first deadline for submission of Romania SAF-T ( the Standard Audit File – Tax ) , known officially as the D406 Informative Declaration, for large taxpayers is January 1st, 2022. Medium and small taxpayers will follow soon after.

Romania SAF-T known as D406 mandated by ANAF with this in mind, we have compiled everything you need to know to be able to prepare for SAF-T.

You can check the post Romania SAF-T to see the technical documents published by ANAF.

What is SAF-T?

The Standard Audit File for Tax (SAF-T) is a new reporting requirement for taxpayers. It’s an international standard that’s designed for the electronic exchange of accounting data between taxpayers and national agencies of tax administration. It was designed by the Organization for Economic Cooperation and Development.

SAF-T is an electronic file that’s based on XML. It’s internationally standardized for sending tax reports from taxpayers to tax authorities, including VAT reporting.

By using SAF-T, the National Agency for Fiscal Administration (NAFA) can review taxpayer’s operations remotely. Meaning they don’t need to conduct fiscal controls or inspections on the taxpayer’s premises.

SAF-T Submission – What Taxpayers Need to Know

What taxpayer should know about  Romania SAF-T, knownas D406

The requirement to submit the Informative Statement D406 has been ordered by the President of the Romanian Tax Authorities.

Submission of the Informative Statement D406 is to be made monthly or quarterly, depending on the fiscal period for VAT. For those that don’t have a VAT code, reporting is to be done quarterly.

The date submission becomes mandatory depends on the taxpayer category as of 31st December 2021…

  • Large taxpayers – starting from 1st January 2022
  • Medium taxpayers – starting in 2022 (no exact date yet)
  • Small taxpayers – starting in 2023
  • Newly registered taxpayers – effective from date of registration. The Informative Statement D406 should first be submitted on the last day of the month following the reporting period. Dependent on the reference date for the category they’re registered in.

Non-resident companies that have a VAT registration number in Romania are also obliged to submit the SAF-T file to the fiscal body. For example, taxpayers who are registered through direct registration, through a tax representative, or fixed establishments.

SAF-T Submission Deadlines

When to submit, Romania SAF-T, knownas D406, deadlines

The Taxpayer’s Guide states that the Informative Statement D406 is to be submitted electronically. The following submission deadlines are to be observed…

  • To be submitted no later than the last calendar day of the month following the reporting period. (Calendar month or quarter, whichever is appropriate, for information other than Inventory and Fixed Assets).
  • To be submitted no later than the deadline for submitting the financial statements for the financial year. In the case of Informative Statement D406 – Fixed Assets.
  • To be submitted by the deadline established by the tax authorities. This can’t be earlier than 30 calendar days from the date of the request. In the case of Informative Statement D406 – Inventory.

SAF-T Data Limit

The D406 cannot exceed 500MB. If the D406 exceeds 500MB, taxpayers will have to use modal reporting to submit the data (reporting the data in several portions – several D406 returns for each taxpayer in the same month).

If, after a D406 statement has been submitted, the taxpayer discovers errors, they may file a rectifying statement.

Romania SAF-T data limited to 500MB

SAF-T Non-Compliance Penalties

D406 legislation has penalties.

There are non-compliance penalties in place for failing to submit the Informative Statement D406 within the deadlines provided. These non-compliance penalties are also in place for submitting incorrect or incomplete information.

Failure to abide by the deadlines or providing incorrect or incomplete information will results in fines in accordance with the provisions of art. 337 of the Fiscal Procedure Code (Law 207/2015).

The fines in place are:

  • Failure to submit the SAF-T file within the legal deadline – fine ranging from RON 1,000 to RON 5,000.
  • Submitting incorrect or incomplete statements – fine ranging from RON 500 to RON 1,500.

SAF-T Grace Period

Non-compliance with SAF-T rules will not be penalised initially as taxpayers will be granted a 3-month grace period for their first reporting.

The 3-month grace period starts when the submission obligation becomes effective for each taxpayer. However, taxpayers must still submit the Informative Statement D406 for the 3-month grace period.

Grace period is until end of April 2020

SAF-T Voluntary Testing

Due to the complexity of the SAF-T file, the Romanian Tax Authorities are providing taxpayers with a voluntary testing program. This will be provided prior to the introduction of the deadlines.

During the period of voluntary testing, all taxpayers can test the Informative Statement D406T, this includes the XML file in SAF-T format. Any transmitted data in the voluntary testing won’t be retained by ANAF and won’t be used in risk analyses/tax inspections.

Suppliers of financial-accounting applications, ERP systems and/or other types of applications involved in submitting the Informative Statement D406 can also take part in the voluntary testing program.

Preparing for SAF-T – S4FN’s Verdict

Last points, S4FN's verdict

Don’t let the 3-month grace period for SAF-T lull you into a false sense of security, we urge you to start preparing now.

Preparing for SAF-T involves extracting huge quantities of data from an ERP. This in itself is a vast amount of work. There’s also the laborious task of filing the data to ANAF in their required format (XML) and taking the preparatory steps necessary to check the accuracy and integrity of the SAF-T files you submit.

S4FN can help to extend the mandatory reporting in SAP with a ready to use add-on. You can utilise the add-on in SAP to generate the SAF-T report with the OECD format that’s accepted by Romania. The add-on has its own configuration to tailor specifically to your needs in SAP.

Implementation is done by importing external transport into your system. To avoid object collisions during implementation, we use a unique SAP-registered name space.

You’re provided with a one-year warranty as part of the package.

You can obtain the annual support package, which covers all new changes to the SAF-T specifications, as well as the solutions of any problems that may arise.

It’s supported for both ECC and S/4Hana systems.

Contact S4FN today to help prepare for SAF-T. Check our D406 solution proposal.

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