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Grace period for SAF-T expires. All reports for 2023 must be submitted by the end of this month26 July 2023

Expiră perioada de grație pentru SAF-T. Toate raportările pentru 2023 trebuie trimise până la finalul acestei luni

The approximately 15,000 companies classified as medium taxpayers enter the last hundred meters with the implementation of SAF-T, given that the grace period they benefited from for submitting reports ends on July 31. The end of this month marks the moment when all SAF-T declarations for the first semester of 2023 must be completed and submitted compulsorily, the sanctioning regime for not submitting these reports being reactivated.

After a six-month grace period, during which no fines were applied for non-filing or incorrect filing of SAF-T reports, medium taxpayers are required to complete their implementations and submit the final returns to the tax authorities for the period so far from 2023.

Depending on the fiscal period they apply, monthly or quarterly, companies will have to submit to ANAF, by July 31 at the latest, either six SAF-T statements (one for each month from 2023), or two such reports
(corresponding to the two quarters already completed).

In a press release published a few months ago, ANAF stated that, in the situation where, as a result of the analyzes carried out, it will identify incorrect or incomplete declarations, it will proceed in the first stage to notify the taxpayers who submitted such declarations, following that subsequently, in the event of non-compliance continuing, to proceed to the gradual application of sanctions.

We remind you that the incorrect or incomplete submission of the SAF-T file can be fined between 500 and 1,500 lei, and the penalties applied will be entered in the tax file of the taxpayers.

Quality tests for correctness of reporting

For a correct implementation, it is necessary to map the accounting accounts according to the ANAF nomenclature, correlate the VAT and tax codes, convert the measurement units and report your own analyses.
A first and mandatory check is done first with the DUK tool, a reporting validator made available by ANAF, with which companies can check if the structure and content of the declaration comply with the technical scheme implemented by the authorities.

In addition to the form validation of the reporting, the SAF-T declaration must also be checked from the perspective of the quality of the transmitted data. Thus, companies must ensure that the data taken in the SAF-T reporting correspond both to the information from the company’s internal accounting systems and to the data reported through the other declarations periodically submitted by taxpayers. If discrepancies occur, the data must be corrected.

And ANAF published a document with a series of consistency tests that companies can do before submitting SAF-T reports, to ensure that the data submitted is correct and complete. Even if they are not mandatory, the tests proposed by ANAF represent an important support for companies in order to ensure the quality of SAF-T reports and avoid errors that may lead to their fines.

The tests recommended by the tax authority cover all sections of SAF-T reporting: Header, Master File, General Ledger Entries, Source Documents. They particularly aim at the correctness of financial-accounting and fiscal data.

Beyond the formal examinations – checking the completeness of certain fields and sections, correlating some information with each other, complying with the calculation formulas for balances or VAT, correct use of amounts in lei and foreign currency, ANAF also recommends a series of correlations of balances.

Thus, in the General Ledger Accounts section:

• total debit balances must be equal to total credit balances after excluding classes 8 and 9;
• the initial balances for a month must be equal to the final balances of the previous month;
• the final balance for each ledger account must be composed of the initial balance and the turnovers declared in section 3 (General Ledger Entries).

In addition, in section 3, the total debit turnovers must be equal to the total credit turnovers, and in sections 3 and 4, the tax amount must coincide with the result of applying the tax percentage (related to the tax code in the ANAF Nomenclature) on the base taxable declared at line level.

All data quality tests recommended by ANAF are available here.


Article published in TaxMagazine

Cristina Săulescu

Tax & Transfer Pricing Partner


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