Large taxpayers will be required to submit SAF-T UA at the request during the tax audit

This obligation is established by the Order of the Ministry of Finance of Ukraine №561 of 15.09.2020 "On approval of Amendments to the Procedure for providing documents of a large taxpayer in electronic form during a documentary audit" (hereinafter – "Order №561"), which enters into force today, August 27, 2021.

Formally, the tax authorities may request a standard audit file (further – "SAF-T UA") from large taxpayers during audits already from this date.

SAF-T is a standardized structure file in XML format, which contains data exported from the original accounting system about the presence and condition of assets, equity, and liabilities, as well as information about changes in the financial and business status of the company for a certain period. SAF-T UA is a variation of this file for Ukraine.

The structure of SAF-T UA consists of the following sections:

• general information about the large taxpayer
• directories on the taxpayer and its activities 
• accounting records in the context of each individual business transaction with details of the transaction performed
• information about documentary support of accounting records:
• actual amounts of purchased (sold) tangible assets, works and services, their quantity and cost
• received/transferred funds
• business operations conducted with tangible assets, waiting to enter into the process of consumption
• business operations with intangible assets
• information reflected in accounting statements and other primary documents, which contain information about the details of the business operation, which are not included in the previous subdivisions
• tax differences.

According to Order No. 561, at the request of the tax authorities during the audit, large taxpayers must provide SAF-T UA within two working days after receiving the request.

The Order also explicitly stipulates that a large taxpayer must have the appropriate software to create SAF-T UA. In their turn, the tax authorities must have the necessary software for receiving documents in the form of the SAF-T UA and publicize the format of electronic documents on their website.

Order № 561 is only a part of the whole concept of implementation of electronic audit (e-audit) for the taxpayers. The Ministry of Finance of Ukraine also published for discussion the draft law "On Amendments to the Tax Code of Ukraine regarding the introduction of electronic audits (e-audit)".

The draft law foresees the obligation of large taxpayers to submit an annual SAF-T UA from 01.01.2025, and all other VAT payers – from 01.01.2027. For non-submission and violation of the SAF-T UA filing procedure, the draft law stipulates penalties in the amount of:

• 100 minimum wages (UAH 600 thousand as of 2021) – for large taxpayers
• 10 minimum wages (UAH 60 thousand as of 2021) – for VAT payers, except for self-employed persons.

SAF-T has already been introduced in such European countries as Portugal, Luxemburg, France, Austria, Poland, Lithuania, and Norway.

So, large taxpayers already need to set up their software to create SAF-T UA.

We will follow the developments on this issue.