The obligation to provide the Lithuanian tax office (STI) with the SAF-T file on demand is foreseen to be implemented in several stages, i.e.:
- Profit seeking private legal entities (except for the certain cases, e.g. economic entities with initiated bankruptcy case, etc.), whose sales revenue exceeds EUR 8 million in financial year 2015, must be ready to submit accounting data as of 1 January 2017 (for year 2017 and upcoming periods);
- Entities whom sales revenue exceeds EUR 700 000 in financial year 2016 – as of 1 January 2018 (for year 2018 and upcoming periods);
- Entities whom sales revenue exceeds EUR 45 000 in financial year 2017 – as of 1 January 2019 (for year 2019 and upcoming periods);
- From 1 January 2020 and subsequent years - all entities, if net sales revenue exceeds EUR 45 000 in the previous financial year.
However, the SAF-T has to be submitted only upon the request from the STI, which will normally be during audits. Based on a recent official comment, it is foreseen that the STI‘s request to provide the SAF-T file for the first year of data provision (2017) is expected to take place in 2019. Furthermore it is clarified that a foreign company that is only VAT registered in Lithuania, will not be required to file accounting data through the SAF-T file.
As we informed you in previous updates, the SAF-T (Standard Audit File for Tax) was developed by the OECD to have companies share tax transactional data in a common way. More countries have implemented the SAF-T, to be provided either on demand or on a periodic basis and is investigated by other countries to implement. However, we have learned that there is no real common way.