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In the Official Journal of Romania no. 1073, dated 9 November 2021, Order no. 1783/ 04.11.2021 of the President of the Romanian tax authorities (ANAF) has been published, on the nature of the information that taxpayers must declare through the standard file, the reporting model, the procedure and conditions of submission, as well as the submission deadlines and dates from which categories of taxpayers are required to submit the Standard Audit File for Tax (hereinafter "the Order").

Summary:
The Standard Audit File for Tax (SAF-T) is an international standard for the electronic exchange of accounting data between taxpayers and tax authorities. This standard was developed by the Organization for Economic Co-operation and Development (OECD) in 2005. The latest version is OECD SAF-T 2.0, on which the Romanian authorities also rely. Informative Statement D406 (SAF-T) is an electronic file, based on a .XML file type, internationally standardized for sending tax reports, including VAT reporting, from taxpayers to tax authorities.

Under the Order, the Romanian tax authorities define the nature of the information to be reported by taxpayers, the format of the informative statement in relation to the Standard Audit File for Tax - Informative Statement D406, the deadlines for submission of this statement by the taxpayer, the dates from which taxpayers are required to submit Informative Statement D406 (depending on their nature), as well as the procedure and conditions for submitting this statement.

Main points of interest for Taxpayers

Submission deadlines
According to the Taxpayer's Guide, Informative Statement D406 should be submitted in electronic format. The submission deadline is:

  • No later than the last calendar day of the month following the reporting period (calendar month / quarter, as appropriate), for information other than Inventory and Assets.
  • No later than the deadline for submitting the financial statements for the financial year, for Information Statement D406 – Assets (fixed assets).
  • By the deadline established by the tax authorities, which may not be less than 30 calendar days from the date of the request, for Informative Statement D406 – Inventory.

The requirement to provide the SAF-T file
By Order of the President of the Romanian Tax authorities, the requirement to submit Informative Statement D406 has been set for each category of taxpayer:

  • For large taxpayers – starting from 1 January 2022.
  • For taxpayers classified as large taxpayers starting from 1January 2022, which were not classified as large taxpayers in 2021 – starting from 1 July 2022.
  • For medium taxpayers – starting from 1 January 2023.
  • For small taxpayers – starting from 1 January 2025.
  • For new registered taxpayers – from the effective registration date, the first submission of Informative Statement D406 should take place on the last day of the month following the reporting period, after the reference date for the category in which they were registered.

Taxpayers must file Informative Statement D406 on a monthly or quarterly basis, in accordance with their fiscal period from a Value Added Tax (VAT) perspective. Taxpayers which are not registered for VAT purposes should submit the SAF-T file on a quarterly basis.

For credit institutions, non-banking financial institutions, financial institutions and insurance/reinsurance companies, classified as large taxpayers on 31 December 2021, the requirement to submit Informative Statement D406 occurs from 1 January 2023.
Investment management companies and administrators of alternative investment funds are also included in this category.

Grace period
The Order also provides a grace period for all categories of taxpayers as follows:

  • Six months for the first reporting, five months for the second reporting, four months for the third reporting, three months for the fourth reporting, and two months for the fifth reporting, for taxpayers which are required to submit the SAF-T Informative Statement on a monthly basis.
  • Three months for the first reporting, for taxpayers which are required to submit the SAF-T Informative Statement on a quarterly basis.

The grace period is calculated from the last day of the reporting period for which it is granted, when the submission requirement becomes effective for that taxpayer.

Modal reporting
In the case of taxpayers with substantial economic activity, which involves a large volume of data (and thus an extensive number of accounting entries and information to be transmitted via the SAF-T file), the procedure for preparation and submission of Informative Statement D406 enables the submission of several Informative Statement D406 forms (modal reporting), each of them containing sections or subsections of the Informative Statement, submitted successively by the taxpayers concerned for the reporting period up to the deadline.

The Romanian tax authorities’ systems ensure that the D406 Informative Statements are received, processed and stored in full.

Technical documentation
The updated and final version of the technical documentation required for this reporting was published in the SAF-T section of the official ANAF website.

KPMG comment

We recommend that all taxpayers (not just Large Taxpayers) should commence their preparations to ensure that they are able to comply with the new requirements, should carry out an in-depth analysis of their internal IT systems and should identify the best and most efficient solutions to collect the information required for Informative Statement D406.

KPMG can support taxpayers with a mixed team of experienced professionals, who specialize in both Tax and IT, and who can help companies and organizations to manage this new challenge.