Standard Audit File in SAP

Sealing of the PIT and CIT tax system, more efficient collectability of receivables, greater income to the budget, shorter tax inspections less cumbersome for taxpayers and a decrease in the costs of fulfilling tax obligations by entrepreneurs – are the main reasons given by the Ministry of Finance for introducing the Standard Audit File (also called Unified Control File, Jednolity Plik Kontrolny, JPK – in Polish). Poland is yet another country that introduces e-inspections and an obligation to send tax information in a structured format.

Schedule of changes

From 1 July 2016 all companies whose turnover exceeds 50 mln EUR annually or which employ more than 250 people will have to provide the tax authority – upon their request – electronic files in an agreed structure, in which taxpayers will be obliged to report accounting books (in their entirety or parts) and accounting documents.

Simultaneously, upon request of tax authorities taxpayers will not be able to provide tax and accounting documentation in any electronic form, as it is currently done.

While, for small, medium and micro entrepreneurs, pursuant to the act on freedom of business activities, the legislator provided for a transition period. In that period – from 1 July 2016 to 30 June 2018 – SME will provide their books and documents in the form of a Standard Audit File based on optionality. Only from 1 July 2018, meaning two years after the obligations start to apply to large enterprises; will it become obligatory for them.

According to the introduced regulations, the Standard Audit File (SAF) will constitute evidence in inspection activities.

What is SAF

SAF are files with an agreed logical structure, through which upon request of the tax body, the taxpayers will be obliged to provide tax books (in their entirety or parts) and accounting documents. The files will be provided using electronic communication or on IT data carriers. In other words, a Standard Audit File is a format of tax books and accounting documents in which taxpayers conducting those books using computer programs will provide them upon request of tax bodies.

In relation to the publication by the Ministry of Finance on 9 March 2016 of the final SAF logical structures, the scope (which is surprisingly broad) of required information was specified.

Currently, the Minister of Finance is expected to issue a regulation that will determine the following:

• the manner of sending data using electronic communication measures,
• technical requirements regarding IT data carriers on which the data will be provided,
• mechanisms ensuring security, reliability and incontestability of data included in the books,
• methods of securing data against unauthorized access.

Currently, the most updated source of information is the regulation draft concerning the Standard Audit File issued on 14 March 2016, in which details regarding the manner of sending files and technical requirements for IT data carriers on which tax books shall be saved and provided, are determined.

SAF structure

The SAF structure will be based on the current version of the SAF-T (Standard Audit File for Tax) file specification. SAF-T is a scheme of data in XML, suggested by OECD in 2005 (updated in 2010 to version 2.0). SAF-T was designed in a way allowing data processing from areas commonly occurring in the accounting system of enterprises divided into:

• main books,
• fixed assets,
• receivables,
• liabilities,
• inventory.

In the process of creating requirements for Standard Audit File s, not only SAF-T file specifications were taken into account, but also accounting documents with the structure agreed based on provisions and national conditions, e.g. electronic invoices. The scheme of the SAF-T 2.0 standard contains only a minimum number of assumptions allowing significant data to be obtained from the accounting system, therefore when implementing SAF-T for the company’s (national) own needs, it should be appropriately expanded.

Information interesting for taxpayers may be guidelines and specifications for the needs of establishing accounting and business tax software. The Ministry of Finance prepared seven various SAF structures adjusted to particular tax and accounting areas used by enterprises. These structures include:

• Structure 1 – accounting books,
• Structure 2 – bank statements,
• Structure 3 – warehouse,
• Structure 4 – VAT purchase and sales registers,
• Structure 5 – invoices,
• Structure 6 – tax revenue and expense ledger,
• Structure 7 – revenue registry.

It is worth highlighting the consequences of failing to apply the provisions entering into force by enterprises. In the case of failing to present tax and accounting documentation upon request of the tax body in accordance with the SAF structure and format, provisions of the Fiscal Penal Code will apply, similar to the case of failing to present the documents in paper.

As we can read in the grounds to the draft of the amending act (parliamentary printed matter no. 3462): “The point is to be able to separate necessary substantial data in an automatic manner, using appropriate IT algorithms. The intention of the solutions being designed is to introduce a new functionality into accounting systems, i.e. the possibility to edit tax books and accounting documents based on a XML standard commonly applied in electronic communication".

Change implementation

Introduction of new provisions constitutes a great challenge not only for financial departments of enterprises, but also for their IT teams responsible for the preparation of relevant changes in companies’ IT systems in order to adjust them to generate data necessary in SAF.

It is hard not to highlight the fact that the technical (and financial) burden of introducing the required changes into the manner of conducting inspections by appropriate bodies (both tax bodies and fiscal inspection authorities will be able to request SAF files) weighs on taxpayers.

They are obliged to ensure that the software used at their company allows data files in the form of a Standard Audit File to be generated.

The requirement to provide the Standard Audit File was introduced by the act dated September 2015, but only in March 2016, the Ministry of Finance published the finally defined SAF logical structures with detailed guidelines regarding the content and the structure of the file. Simultaneously, enterprises have a little time to adjust their IT systems to the tax collector’s requirements. In addition, there are quite a few changes necessary in large companies that use e.g. the SAP integrated management system. The scope of changes necessary to introduce in IT systems depends on the specificity of the company’s business activities, complexity of processes using data from numerous areas and necessity to adjust the entire solution to strictly determined requirements.

Standard Audit File in SAP

In order to enable companies working with SAP to adjust their systems on time, BCC (now All for One Poland) prepared a solution, which allow users to prepare Standard Audit Files directly in the SAP ERP system, as well as to generate their statement in the form of .XML files, allowing the statements to be sent in an electronic form (also electronically). The Standard Audit File in SAP has been developed by BCC since January 2016 based on subsequent information from the Ministry of Finance specifying the requirements regarding taxpayers. Therefore, the specialists from BCC are prepared to support customers in adjusting their SAP system to generate tax and accounting data in the SAF form in accordance with the provisions of the new tax ordinance.

Elements of the Standard Audit File package in SAP offered by BCC (now All for One Poland) include:

• A set of ready functionalities with implementation methodology,
• Analysis of the scope of works necessary to fulfill the legal requirements in a given company,
• Adjusting the product to the specific needs of a given organization.

The solution in the form of the Standard Audit File is offered within the range of All for One SAP Add-ons solutions. It is the first and so far, the only product on the market addressed to companies with the SAP ERP system, which allows the new requirements of the tax and fiscal inspection bodies to be fulfilled.