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Standard Audit File in Poland - significant changes from 1 January 2017

From 1 January 2017 most taxpayers in Poland are oblige to provide VAT data in a unified format – the Standard Audit File for Tax (SAF-T). Only micro businesses (those that employ, on an annual basis, fewer than 10 employees and that have sales or balance sheet assets of €2 million or less)  will have to start filing VAT data in the SAF-T format since the beginning of 2018.

SAF-T will need to be filed on monthly basis, without tax authorities’ request, by 25th day of the month following the month to which SAF-T file pertains. In practice, this means that on 27th February 2017 taxpayers have to be prepared for submitting data of VAT records in a SAF-T form to the tax authorities. Polish Ministry of Finance published a specification how the files should be submitted. A collected data needs to be transformed into the required xml files in an appropriate format and then validate completeness and data type accordance for every SAF separately. Afterwards, the prepared SAF  is  put in appropriate folder and downloaded in order to deliver it to a tax authorities. Then, SAF needs be compressed, divided into appropriate size packets, encoded and signed with a licensed e-certificate.


Poland is the fifth country after Austria, Luxembourg, France and Portugal which implemented SAF-T.


Moreover, from 1 July 2018, at the request of the tax authorities, taxpayers are oblige to provide data in a predefined electronic format (xml file in the prescribed form and logic) in the scope described below:

  • accounting records
  • bank statement
  • warehouse
  • invoices


This obligation applies already to large companies (those that employ, on an annual basis, more than 250 employees and that have sales over EUR 50 million or balance sheet assets over EUR 43 million).   In order to meet this new obligations, modification of an accounting system and, in some cases also bookkeeping rules, will be required. The SAF format will provide tax authorities with easy access to accounting data. The efficiency of tax audits is expected to rise by introducing SAF functionality because the tax authorities will be able to conduct an automatic comprehensive check of tax records and accounting documents.


Failure to submit a requested data in the SAF format as well as an inclusion of inaccurate data into a report can be classified by the authorities as offences under fiscal penal law. Finding the taxpayer guilty of such an offence may lead to the person responsible for financial matters to be penalized with a fine in accordance with Art. 80 of the Tax Penal Code. The maximum sanction for non-submission SAF format can amount to as much as PLN 3m. In case of inclusion of false data in SAF, the potential sanction could reach PLN 6m.



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