Obligation to Submit the D406 Informative Statement (SAF-T) Romania
The Order 1783/2021 on the nature of the information (Official Gazette (Part I) no.1073, dated November 9, 2021 ) states that Romanian taxpayers must send standard tax control files through the D406 Informative Declaration (SAF-T).
That obligation is mandatory for high-rate taxpayers as of 1 January 2022. For medium-rate taxpayers, the reporting obligation will occur from 1 January 2023, and for low-rate taxpayers from 2025.
The D406 form must be submitted monthly or quarterly, following the applicable tax period for value added tax (VAT). Taxpayers who are not registered for VAT purposes must submit the SAF-T file quarterly. The standard frequently reporting obligation does not cover information about assets and stocks, which must be reported separately, taking into consideration terms specified in financial statements reporting or set out by tax authorities.
Non-resident companies registered in Romania for VAT purposes are also covered by the requirements.
The Romanian tax authorities (ANAF) require SAF-T to be sent in PDF file with an XML file attached.
Structured SAF-T implemented in Romania contains more than 390 mandatory tax and accounting elements that must be reported by each taxpayer. The structure covers 10 totally different sub-statements. Each of the 10 sub-declarations covers a distinct module/field/economic process such as: customer balance, supplier balance, accounting balance, inventory balance, general register, invoices issued, invoices received, stock movements, receipts and payments, and fixed assets. Each sub-declaration may be divided into more detailed files, and so on.
Failure to submit the D406 Informative Declaration, or incorrect or incomplete filing, found by ANAF within the deadlines provided by law, will attract penalties for taxpayers. However, taking into account the complexity and novelty of this reporting obligation, the Romanian government has introduced a six-month grace period. This means that taxpayers who do not meet the requirements on time will not be penalized.
The Romanian tax authorities are considering removing some reporting obligations (i.e. form D394, which contains data about domestic sales and purchases), once SAF-T is in force.
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