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.


I refer for clear understanding our debrief of 'SAF-T for Poland and SAP' and for info about our 'SAP add-on for SAF-T Poland'.

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.

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

sap certified logo
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.

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

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.

Today, 25 August 2016,  is the deadline of the monthly VAT SAF-T 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

SAP add-on solutions for SAF-T 

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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.