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In Europe SAF-T is now in force in Austria, France, Lithuania, Luxembourg and Poland. We understand that Germany, UK, Ireland, Norway and the Czech Republic are most likely next to introduce SAF-T. Lithuania is expanding its SAF-T. Starting October 1, 2016 all VAT-registered taxable persons, - including foreign companies registered for VAT - will be required to submit a SAF-T file in XML format to the LT Tax authorities on a monthly basis.

Filing SAF-T will be mandatory for almost all companies with net sales for FY2015 exceeding EUR 8 million. The first monthly mandatory submission date is 21 November 2016. The submission of the SAF-T files on request to the Lithuanian Tax Authority or other institutions starts on 1 January 2017. 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. The controlling authorities are State Tax Inspectorate, Customs Office, Financial Crime Investigation Service, Social Insurance Fund Board.

Date in force

Who is impacted?

1 January 2016

Recommended for all private legal entities, public sector entities and other non-profit legal entities, foreign legal entities’ branches and agencies

1 January 2017

Mandatory for all profit seeking private legal entities, whose net sales revenue exceeded 8 million EUR in 2015

1 January 2018

Mandatory for all profit seeking private legal entities, whose net sales revenue exceeded 700 thousand EUR in 2016

1 January 2019

Mandatory for all profit seeking private legal entities, whose net sales revenue exceeded 45 thousand EUR in 2017

1 January 2020

Mandatory for all profit seeking private legal entities, whose net sales revenue exceeded 45 thousand EUR during the period preceding the last financial year

When a treshold is triggered once, the accounting data needs to be mandatory submitted ongoing, even if net sales revenue in subsequent accounting periods will be below the treshold.


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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 Key Group.

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.