Romania: Implementation of the Standard Audit File for Tax (SAF-T)

The Romanian tax authorities published the draft requirements regarding the introduction of SAF-T in Romania, and we mention below the main information published in the second draft, dated 16 September 2021.

The aim of the tax authorities is to perform some electronic verifications, without having to carry out fiscal controls or inspections at the taxpayer’s headquarters.

The implementation of this standard presupposes the obligation of the taxpayer to submit a declaration containing information from the fiscal and accounting records, respectively the informative declaration D406, an XML-based electronic file.

Among other things, SAF-T will contain the following:

• Master files – this section contains subsections for more information, such as:

• Accounting accounts/journal register;
• Customers (identification data, analytical account, initial and final balance debtor/ creditor);
• Suppliers (identification data, analytical account, initial and final balance debtor/ creditor);
• Tax table (specific tax information);
• Table of units of measurement;
• Table of types of analysis (information on the structure of the taxpayer’s cost centres);
• Table of types of movements;
• Products;
• Stocks;
• Owners (details regarding stock owners);
• Assets.

• Accounting records – journal register – information on accounting records, at transaction level, including analytical accounting accounts.

• Source documents – information about source documents such as:
  • Sales invoices;
  • Purchase invoices; › Payments;
  • Movement of goods;
  • Asset transactions.

All Romanian legal entities and units without the Romanian legal personality of foreign legal entities, which have the obligation to prepare double-entry accounting, are obliged to submit SAF-T.

Other entities are also required to submit SAF-T, such as Romanian permanent establishments of foreign legal entities, associations and non-resident companies registered for VAT purposes in Romania.

SAF-T will be submitted monthly or quarterly, depending on the VAT fiscal period, and, for entities without a VAT code, the reporting will be conducted quarterly.

The following proposals have been mentioned as the implementation date for SAF-T:

• large taxpayers (as of 31 December 2021) are obliged to submit declaration D406 from 1 January 2022 onwards,
• medium taxpayers (as of 31 December 2021) are obliged to submit return D406 from 1 January 2023,
• small taxpayers (as of 31 December 2021) must submit return D406 from 1 January 2025 onwards.

Although it is not clearly specified, it seems that non-resident companies registered for VAT purposes in Romania would be required to submit SAF-T starting from 1 January 2025.

It is proposed that the reportable information within SAF-T for non-Romanian taxpayers registered for VAT purposes in Romania, with no obligation to prepare Romanian accounting, is the following:

• Header
• Master files with specific subsections:
  • Tax table
  • UOM table (unit of measure table)
  • Products

• Source documents with the following subsections:
  • Sales invoices
  • Purchase invoices

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