RSM Poland


VAT records in SAF-T

VAT records sent on an ongoing basis in the Standard Audit File for Tax (SAF-T)


On Friday 13th & 19th May 2016 the Polish Parliament passed an act amending the Tax Ordinance Act and certain other acts that, i.a. introduces an obligation of automatic monthly transfer of information on VAT records, referred to in article 109 paragraph 3 of the Act on Tax on Goods and Services (Journal of Laws of 2011, No. 177, item 1054 as amended). The transfer is to be performed within the logical structures of the Standard Audit File for Tax (hereinafter also referred to as SAF), i.e. it will apply to entities that keep tax books using computer software. The change was proposed during the work of the permanent parliamentary subcommittee for tax system monitoring on the amendment of the Tax Ordinance Act, aimed at the introduction of a clause against double taxation into the Polish legal order, and was passed by the parliamentary Public Finance Committee (document 464).

The concept of the Standard Audit File for Tax (SAF-T) itself has already been discussed in our publications twice (Tax Alert 2/2016, Tax Alert 8/2016). The idea behind the SAF comes down to the transfer of tax books and accounting documents in electronic form, in accordance with a defined logical structures, required by the tax or tax inspection authorities from entities that keep their tax books using computer software. Final (as for now) versions of SAF logical structures are available on the website of the Ministry of Finance in the tabs of the Tax Administration and Tax Inspection (link).

Under the provisions of the amending act, it is highly probable that from 1 July 2016 the entities that keep tax books in an electronic format will be additionally required to automatically send monthly information on their VAT records. It should be assumed that by "information on the conducted VAT records" the legislator meant the data contained in these records and not only the information on the fact of recording. The deadline for its provision is to be the 25th day of the month following each consecutive month for which the information is provided.

Both in the case of the provisions on the transfer of tax books and accounting documents to the tax authorities at their request and in the case of regulations relating to automatic monthly transfer of VAT records, the legislator provided for transitional periods for the category of micro, small and medium-sized enterprises within the meaning of the Act on Freedom of Economic Activity (Journal of Laws of 2015, item 584, as amended). Within these periods entrepreneurs will have a possibility and not an obligation to provide information on VAT records in electronic form in accordance with SAF logical structures. These periods, depending on the category of entrepreneur, differ slightly from those adopted for the SAF.


Entrepreneur category

Transitional period:

Deadline for transfer (after the effective date of the provisions, i.e. after 1 July 2016):


VAT records within SAF


VAT records

within SAF




on demand

first information by 25.08.2016

(for July 2016)

Small and medium

1.07.2016 – 30.06.2018

1.07.2016 – 31.12.2016

on demand

first information by 25.02.2017

(for January 2017)


1.07.2016 – 30.06.2018*

1.07.2016 – 31.12.2017

on demand

first information by 25.02.2018

(for January 2018)


* the legislator clarified that these entities, similarly to small and medium-sized enterprises, will be required to transfer tax books and accounting documents of a defined logical structure on demand only from 1 July 2018.


The above means that large enterprises will already be required to transfer the first records by 25 August 2016, whereas micro, small and medium-sized enterprises will be required to upgrade the used accounting system and adjust it to the requirements of the logical stricture of the SAF significantly sooner than it was originally assumed in the regulations introducing the Standard Audit File for Tax.

Moreover, it must be noted that so far the Minister of Finance has not issued a regulation on the technical aspects related to the data transfer within the SAF, i.e. on the manner of the transfer and the technical requirements for data carriers on which the books, parts of the books and accounting documents may be saved and transferred.


If you have any questions or need to discuss the topic, you are strongly encouraged to contact our expert, Tomasz BEGER:


tel. +48 61 8515 766

fax +48 61 8515 786