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From 1st July 2016 onwards it is required to provide SAFT-PL files in XML format on request of the PL Tax authorities. 

Filing SAF-T will be mandatory for large taxpayers: employ more than 250 people or 50 million EUR sales revenue irrespective of whether they are established in Poland or not. Per 1st July 2018 this extended to taxpayers with more than 9 employees or 2 million EUR sales revenue.

Foreign businesses not having a branch and/or fixed establishment but that are registered for VAT in Poland fall within the scope of the above reporting requirement when above conditions are met.

On 19 May 2016 the Upper Chamber of the Polish Parliament passed a bill on the amendment of provisions of the Tax Ordinance and of some other acts. According to the bill adopted by the Parliament, the obligation to generate VAT reports in a SAF-T data format and their monthly reporting to the tax authorities will apply initially only to the largest enterprises for each month begun on or after 1 July 2016.

It means that Large Enterprises will be obliged to file VAT reports in the SAF-T data format already on 25 August 2016. Thus, Large Enterprises will be obliged to submit in monthly period VAT register in SAF-T format (according to JPK_VAT structure 4 – VAT register) even if the VAT reporting period is quarterly.


Taxpayers will be obliged to submit the SAF-T format:


  •  on request in the case of a preliminary tax inquiry, a tax audit and tax proceedings;
  •  monthly mandatory – with respect to the VAT sales and purchases records only (Article 109(3) of the Value Added Tax Act of 11 March 2004 (VAT records) by submit monthly a SAF-T file that contains VAT sales and purchase records.

The first requests to submit audit files at their discretion will likely take place around September 2016. The monthly VAT reports on 25 August 2016.


Not complying with this obligation will not only negatively affect the position of taxpayers during a tax audit but also result in unforeseen tax costs as penalties will be levied.

‘Final' version of the logical structures of the Standard Audit File (SAF) was published by the Ministry on 9 March 2016 including FAQ.

Besides introduced now in Poland similar EU obligations exist already in Portugal (2013) Luxembourg (2013), Austria (2009), France (2014), Lithuania (2015). More and more tax administrations around the world are implementing electronic auditing of a business’ financial records and systems.


Final version of SAF-T structures


  1. Structure – accounting records
  2. Structure – bank statement
  3. Structure – warehouse
  4. Structure – VAT register
  5. Structure – invoices
  6. Structure – tax register of revenues and expenses
  7. Structure – evidence of revenue

SAP and SAF-T Poland


SAP developed currently only an extraction tool for SAP ECC 6 and higher version. The generation of the SAFT-PL XML files is not included. Certain companies use “older versions” of SAP (SAP R/3) and will not be supported by SAP.

Based on SAP's OSS notes, SAP provides only at the moment a functionality for gathering and downloading some transactional data. However, it is not the complete set of data required and the creation of the SAF-T file for the tax authorities is also not included. The functionality will also only be available for companies established in Poland and not for companies with a foreign Polish VAT registration.

That means lots of SAP companies will face compliance problems and this is just a start point as SAF-T will as you know expand globally.

In order to be able to comply with the requirements and provide the XML file on request in time, tooling needs either to be developed or purchased.


Our solution


A SAFT-PL tool that already works for Portugal that includes also strategy for downloading the relevant data from SAP for older SAP versions.


The basic design for a workaround solution is to extract the raw source data from the relevant SAP tables and use software tools to load the relevant data from the source SAP tables, perform additional mappings and data preparations and create the required XML files.

We offer 3 solutions:


  • A software application called Audit Command Language (ACL). This software is commonly used by auditing firms, tax authorities and internal audit departments. The process will be that the client will download the data from SAP and make it available to the Phenix. Phenix will then generate the XML files and some control reports and provide these files and reports available to client for submission.
  • A tool in MS Access in combination with a specific user interface for extracting the data from SAP. The result is a full in-house solution for the client.
  • New: A SAP add-on solution

SAF-T VAT solution for Poland, Lithuania and Norway

This integrated SAP solution is developed together with a certified Global SAP Application Partner. The partner's core business is to develop SAP certified add-ons and many well-known multinationals companies have implemented it for the comparable submission of electronic data.

sap certified logo
The SAF-T SAP add-on solution is now available for Poland, Lithuania and Norway.

If all 3 countries are purchased all at once a package discount will apply. All inclusive means implementation, training and 1 year of free support and maintenance for bug-fixes & legal updates. We have an office and management in Poland and local people provide helpdesk support in English and Polish.

More detail also including an overview of the requirements for Lithuania, Norway and Poland and the challenges companies need to overcome when SAP is run can be found in attached slide deck.

Strategic partnership

SNI and KEY Group have formed a strategic partnership to leverage the synergies between KEY Group's tax and SAP services and SNI’s SAP add-on solutions.

The partnership positions the KEY Group as a preferred partner of SNI. Through this strategic alliance, the two organizations will bring to market SAF-T SAP add-on and web based portal solutions. We work for some of the world’s biggest businesses in the areas of tax, ERP consulting and technology.

The service will be provided by our core team and supported by our operations in Poland, The Netherland and Turkey. This team is led by experienced and highly regarded Tax and SAP professionals who will be actively involved in all stages of the work we undertake. Our senior team is supported by experienced and motivated professionals with backgrounds as tax lawyers, chartered accountants and SAP (technical architects and functional).

We have the capacity to provide the services you require and sufficient flexibility should that need grow or reduce over time. The team has enormous experience in this type of SAP work including having managed migration / on-boarding projects and on-going (tax) performance advisory services for a number of global businesses.

Case studies outlining similar projects could be provided.

See also Innovation and tax audits and Mandatory e-audit files

Last Thursday - 25 August 2016 - was the deadline of the monthly VAT SAF-T PL submission. We have submitted for all our MNC clients our SAF-T VAT files. Our generated SAF-T VAT file reconciles with the numbers of the Polish VAT return, are tested and signed off by our clients and have also been checked with the official tool of the Ministry of Finance. This is tool is not only for testing but can be used for submission when a company has an electronic signature.

More detailed background information about SAF-T compliance and planning



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SAP add-on solutions for SAF-T 


Written by Richard Cornelisse
 Richard LinkedIn

Richard advises multinational businesses in improving the efficiency and effectiveness of their Indirect Tax Function and Tax Control Framework.

He started his career as a manager at Arthur Andersen and then became a partner in EY where I led the indirect tax performance team for Netherlands and Belgium. Currently he is a senior managing director of Phenix Consulting.

Richard has over 20 years’ experience advising clients on international VAT issues. He is specialized in the tax aspects of financial transformations, shared service centre migration, and post merger integration work. Richard is also somewhat of a mentor, giving back to the profession. If you are interested in conversation and discussion, please feel free to contact him.