30 / 09 / 2016

Our thoughts about the first submission of an SAF-T file

30 / 09 / 2016

Our thoughts about the first submission of an SAF-T file

A list of the most frequent challenges large companies face during the first two months of SAF-T reporting, along with suggestions for overcoming them, has been compiled by experts from Onwelo, which is a company that specialises in financial-reporting automation, including with regard to SAF-T.

One: Is the data complete? 

“Up until now businesspeople only submitted VAT declarations and, let’s face it, nobody paid much attention to the data when submitting a VAT declaration: the main thing was whether the sums added up. But in an SAF-T file the transactions that make up the declaration need to be shown. This means not only the amounts, but also the document numbers, the contact details of the counterparties and the dates”, said tax adviser Marcin Madej, who also specialises in the development of finance and tax applications at Onwelo.

And here the first difficulty arose: it turned out that we were not paying that much attention day-to-day to whether we had, for example, the tax ID number or address of the counterparties we received the invoices from. This was why many companies were forced to enter either nothing at all, or “no data available”, in obligatory fields of the purchase section of their SAF-T VAT reports, which proved very problematic indeed once the Ministry of Finance began to analyse them.

Conclusion number one
Check that your data is complete. Have a look at your database of counterparties (suppliers and customers). If any information is missing, it is important to find it and enter it ahead of any reporting deadlines.

Two: Do you have high-quality data?

Many times when adapting data to the required reporting structure of the SAF-T files, Onwelo advisers have seen, for example, the tax ID numbers of counterparties in the form 0000000000 or 1111111111, or only the town or city component of their addresses instead of their full addresses. This meant that many companies once again had to resort to simplifications such as the string of ten zeroes above.

Conclusion number two
The data that we have already filled in are not necessarily accurate. As well as being correct, the data we enter into our systems should be consistent with the data entered on the counterparty invoices. It is worth reviewing counterparty data regularly and keeping it up to date.

Three: there is no consistent approach to data presentation

It became clear in the course of preparing to compile data for the SAF-T just how complicated and largely manual a process it is. Often there is no consistent approach to data presentation in the reports. Some data are reported only as amounts, and some areas of the VAT registers are prepared in detail.

This meant that large companies had to decide whether to present aggregates in the SAF-T or to search for detailed data. Very often I came across extreme approaches, including presenting aggregates in the form of one line for a single field in VAT declarations. The standard approach, though, seems to be to present some of the data in individual, stand-alone detail and some in cumulative form. That’s been enough to get by for the time being. But if the Ministry of Finance starts analysing the data, it might not be enough simply to go on presenting aggregates, said Marcin Madej.

This meant that large companies had to decide whether to present aggregates in the SAF-T or to search for detailed data. Very often I came across extreme approaches, including presenting aggregates in the form of one line for a single field in VAT declarations. The standard approach, though, seems to be to present some of the data in individual, stand-alone detail and some in cumulative form. That’s been enough to get by for the time being. But if the Ministry of Finance starts analysing the data, it might not be enough simply to go on presenting aggregates, said Marcin Madej.

W związku z tym duże przedsiębiorstwa musiały podjąć decyzję czy zaprezentować agregaty w JPK, czy szukać danych szczegółowych. Kilkukrotnie spotkałem się ze skrajnym podejściem, łącznie z prezentowaniem agregatów w postaci jednej linii dla jednego pola w deklaracji VAT. Standardem natomiast wydaje się być sposób prezentacji części danych na poziomie pojedynczym, a części w postaci skumulowanej. Na dziś takie rozwiązanie zdało egzamin, ale jeśli MF zacznie analizować dane, podejście polegające na prezentowaniu agregatów okaże się kłopotliwe – komentuje Marcin Madej.

Conclusion number three

To sum up, the process of preparing SAF-T VAT reports at large companies has revealed failings in a number of areas, which these companies are now working to repair. “Don’t wait until the last minute. Given we know that the new reporting requirements will affect us from either January or February next year, we can start doing things now that will save us a lot of work at the beginning of 2017”, advised Marcin Madej.