The Romanian National Agency for Revenue Administration (ANAF) has presented new guidelines for the launch of its version of the OECD Standard Audit File (SAF-T) for large taxpayers. On January 1, 2022, the six-month period for the monthly SAF-T reporting requirement for the first group of large taxpayers. This means that the first submissions for transactions from January 2022 will not now be required before June 30, 2022. All taxpayers should participate in the program by early 2023.

For VAT registered non-resident companies, there is a limited data set requirement.

SAF-T in Romania is known as “deklaraiei informative” ( Informative Statement) D406 return and is in XML format. Voluntary testing is currently underway prior to mandatory launch in 2022. It will be phased in gradually between January 2022 and January 2023 – subject to a grace period of six months. E-invoicing in Romania was discussed on implementation in 2022 but no further details.

Find out which countries have implemented SAF-T.

Obligations to submit SAF-T in Romania – monthly reporting

D406T returns will be payable monthly in line with VAT refund obligations. There will be an initial grace period of 6 months during which declarations will not have to be completed under the new regulation. D406T is due by the last day of the following month. In the case of taxpayers with a turnover not exceeding RON 500,000 per year, it is quarterly in accordance with the obligation to settle VAT. Also applies:

• Annual reporting of capital or fixed assets with maturity by January 31st; and
• Inventory movement reports on request should be available within 30 days of the request by the ANAF.

The first declarations for large taxpayers, which are published on the ANAF website, therefore expire in February 2022 – but with an optional six-month grace period. The implementation date for medium-sized enterprises has not been made public. Small enterprises will start in January 2023.

However, as mentioned above, there will be a 6-month penalty-free period for the launch of SAF-T in 2022.

Structure of the SAF-T D406T

ANAF consults with business groups on the development of transaction-based reporting obligations. It will follow the OECD model (v2.0). It has now released specifications including:

1. SAF-T_Romania_SchemaDefinitionCodes.xlsx: structure of the Romanian SAF-T format
2. Romania_SAF-T_Financial_Schema.xsd – acceptable schema in XML format
3. Appendix JPK – Structura_D.docx – validation rules for the tax office

The proposed structure is as follows:

• Header – company details and software used for preparation
• Material files
  • General ledger accounts
  • Customer Details
  • Supply
  • Tax table
  • OUM table
  • Analysis type table
  • Movement
  • Product Details
  • Inventory
  • Book of fixed assets
• General ledger – transaction-level details to help you calculate taxes
• Source documentation
  • Invoice
  • Purchase invoices
  • Payments
  • Stock movements
  • Fixed asset movements (billed annually)

Voluntary reporting began in August, and large taxpayers will be required to submit SAF-T applications from the beginning of 2022. Firms are expected to submit three accounting records per month (journals, receivables and liabilities). A standing book will be required annually. The fifth ledger, Inventory, will only be available upon request.

How do I compile a D406 statement?

• Prepare XML files according to the list above
• Use ANAF’s design verification tool to validate structures
• Create a D406 in PDF format with attached XML with a digital signature of the taxpayer issued by ANAF
• Make sure you get the electronic ANAF receipt

How to assemble SAF-T D406?

Taxpayers have three options to submit their XML SAF-T D406:

1. With customized ERP and accounting information;
2. Using an XML editor to convert your accounting information;
3. External specialized service provider that can draw up, make and file the declaration on behalf of the taxpayer.

OECD SAF to harmonize the exchange of tax data

SAF-T is the OECD standard data exchange scheme between tax authorities and companies. It was developed in 2005 and so far has been used in: Poland; Norway; Portugal; France; Luxembourg; Austria; and Lithuania. Hungary wants to be the eighth country in two years.

The Standard Audit File for Tax has also been introduced for tax countries such as: