Together with our Romanian partner, Pincvision is able to assist in assessing the required data fields and ultimately create and submit the SAF-T .xml in Romania. Please get in touch with us in case you require more detailed information. We do urge to start already with the assessment even if the obligation only starts in 2023 as the collection of the required data can be challenging. Therefore, we advise to start a pre audit soon.
Taxpayers required to submit the SAF-T file in Romania
- Romanian legal entities and the foreign businesses without Romanian legal personality but with a Romanian Vat Registration number will have the obligation to prepare and submit the standard SAF-T fiscal control file through the Informative Declaration D406, as follows:
- taxpayers already in the category of large taxpayers - from January 1, 2022 (reference date for large taxpayers);
- taxpayers already in the category of medium taxpayers – as from 01.01.2023;
- taxpayers already in the category of small taxpayers and foreign businesses- as from 01.01.2023.
- Companies that are part of VAT groups or of a tax group that apply the tax consolidation system in the field of profit tax will report the SAF-T file individually and not at group level.
- Non-resident companies registered for VAT purposes will have the obligation to draw up and submit Information Return D406 in a simplified form.
The periodic D406 VAT form
The periodic form follows the same period and deadline of the applicable VAT reporting period and contains:
- General Ledger - Journals
- Accounts Receivable – Customer Master Files, Sales Invoices & Payments (on line item level)
- Accounts Payable – Supplier Master Files, Purchase Invoices & Payments (on line item level)
The on-demand form (within the term established by the fiscal body, which may not be less than 30 calendar days from the date of request) – for information on Inventory.
The annual form (follows the deadline for submitting the financial statements of the financial year) contains:
- Fixed Assets – Asset Master Files & Inventory Movements
From the first reporting, a three month grace period is granted to the taxpayer wherein no fines are issued for non-compliance or non-submitting of the D406 period form. After this period a fine may be imposed on a taxpayer who untimely issues a D406 form, does so incorrectly or fails to include the EC sales recapitulative statement in the same D406 form. More precisely:
- A fine of 1,000 to 5,000 RON (EUR 200/ 1,000) may be imposed for not submitting the required form within required timeframe, respectively:
- A fine of 500 to 1,500 RON (EUR 100/300) may be imposed for an incorrect or incomplete submission.
In case of detection of errors in its completion, the SAF-T file is considered to be submitted on time if the error is remedied and the return of the declaration is made within five working days from the expiration of the legal submission deadline.
If by the end of the grace period all preceding reports are not yet submitted or corrected, fines will be retroactively imposed.
Technical format of D406
- XML format based on OECD 2.0 scheme.
- Accompanying PDF file with same data must be filed alongside the XML file (this can be generated with a tool that the Romanian authorities offer).
- The final PDF/XML D406 return has to be digitally signed with a qualified digital certificate.
- XML files larger than 500MB must be submitted in parts, division of such files must be made as sub-sections (which then cannot be further split into smaller parts).
- A corrective report automatically replaces the previous incorrect report if the taxpayer submits the corrective report for the same period.
- Section contains overall information about SAF-T file. In particular, taxpayer data are provided in this section including registration number, company name, address.
- This section contains master data about suppliers, customers, tax codes, company products, inventory, assets and others.
<General Ledger Files>
- This section contains accounting records at analytical level. Reporting needs to be in line with Romanian Chart of Accounts.
- Information about taxpayer source documents are presented in this section. In particular data about sales and purchase invoices need to be reported on very detailed level.
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