From 27 August 2021 large taxpayers are obliged to submit Standard Audit Tax filings at the request of the Ukrainian tax authority no later than two business days following the day the request was received as part of an audit (para. 85.2, the TCU)*
From 1 January 2025 mandatory for large taxpayers to submit Standard Audit Tax files (Draft Law No. 6255 dated 2 November 2021)
From 1 January 2027 Mandatory for all VAT payers to submit filings (Draft Law No. 6255 dated 2 November 2021)
*The Ukrainian State Tax Service is currently updating the taxpayers' electronic cabinet for SAF-T UA. All large taxpayers are likely to receive requests for SAF-T UA after the State Tax Service resumed its tax audits on 8 January 2023
Main information provided in SAF-T UA:
1 Accounting policies and description of accounting approaches
2Detailed description of business transactions, including transaction coding and characteristics
3 Accounting and tax information, including: transactions by date, number, source document name, and amount
4 Source documents, accounting certificates, etc.
For the SAF-T UA structure follow the link On approval of amendments to the Procedure... | No. 561 dated 15 September 2020 (rada.gov.ua)
SAF-T UA structure
I. Title
III. Journal of Accounting Records
1.1 General information on the LTP (Large Tax Payer): date of establishment, software, authorised persons, information on owners, contacts, etc.
3.1 Accounting transactions, including: dates, number and names of primary documents, accounting entries, transaction amounts without VAT, VAT
II. Directories
IV. Information about accounting records documentation
2.1 Accounting policies
2.2 Transaction directories: description of types of business transactions, including transaction coding and characteristics
2.3 Owners (founders): information on owners and their contributions to capital
2.4 Balance sheet / current accounts (by accounts / subaccounts and analytics)
2.5 Counterparties
2.6 Products (goods, works, and services)
2.7 Inventories
2.8 Non-current assets
4.1 Information on sales (in detail)
4.2 Information on acquisition / procurement (detailed)
4.3 Information on payments not related to the sale / purchase of goods, works, and services
4.4 Inventory transactions
4.5 Transactions with non-current assets
4.6 Information on accounting certificates and other source documents
V. Tax differences
5.1 Tax differences that an entity may have
SAF-T UA: Key issues
- LTP software readiness to form SAF-T UA
- Extensive detailed list of information to be provided as part of, and together with, SAF-T UA (Annex to Order No. 561: 5 sections and 17 subsections)
- Requirement to back accounting data with source documents (in electronic form, or, if there is no obligation to prepare electronic documents, in Adobe PDF format)
- Requirement to provide copies of administrative documents concerning approval of accounting policies and other detailed information along with SAF-T UA
- Tight deadlines for providing information (subpara. 85.2, the TCU: for a taxpayer in case of an audit by the STS: no later than two business days following the day the request is received)
Main preparatory efforts
Software for SAF-T UA submission
Creation of SAF-T UA archives for the period of the State Tax Service audit
Checking SAF-T UA generated files
Implementing SAF-T in Ukraine
How KPMG in Ukraine can help?
1. KPMG specialists analyse your Accounting Policy and provide recommendations on what you can improve and/or assist directly in improving your Accounting Policy
We analyse your Company’s accounting policies and key accounting processes. We provide recommendations on how you can improve your accounting policy and/or update your accounting policy with direct input and assistance from KPMG professionals to properly formalise accounting procedures, taking into account the important tax and documentary aspects specific to your Company’s business.
2. Tax diagnostics are carried out to identify potential tax risks in Company activities and measures are then planned to mitigate risks (optional)
We help you identify potential tax risks and estimate their amount. We provide recommendations on measures to mitigate any risks identified.
3. We verify the accuracy of any mandatory data prepared by your Company for SAF-T UA filing (in case SAF-T UA files are independently generated by your Company)
We check the data that your Company will prepare for conversion to xml documentation against the requirements set out in the applicable Ukrainian legislation and the latest tax authority clarifications (if it is agreed that the SAF-T UA will be prepared by your Company and/or your Company’s IT provider).
4. Terms of reference will be prepared for cooperation between your Company's accounting department and the IT provider
We help your Company prepare terms of reference for your Company’s IT provider in accordance with legal requirements and the latest clarifications from the Ukrainian tax authorities. We assist in establishing communication between the accounting department and your Company's IT provider.
5. Methodological accounting and tax support for providing recommendations / advice for preparing SAF-T UA depending on your requests
We offer recommendations for the process of preparing your Company’s SAF-T UA based on selecting mandatory and other data for the filing. We provide advice on importing data from your Company’s accounting registers into a tabular (Microsoft Excel) format and an xml file. We advise on Company tax and accounting requests in the process of forming a SAF-T UA.
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