Periodic reporting requirements around the EU

Periodic_reporting

Introduction

In a previous blog post we discussed several real-time reporting models for VAT. Now it’s time to discuss periodic reporting solutions and especially those implemented in the EU. Following our own research, 10 out of 27 EU Member States implemented such a solution at the moment of writing (See Table 1). In the following we will first explain what periodic reporting for VAT is, after which we explain the differences between periodic reporting and real-time reporting. We will show that although periodic reporting can result in positive effects, real-time reporting offers more benefits to both public and private actors.

What is periodic reporting?

Periodic reporting (sometimes called Periodic Transaction Controls - PDC) refers to the obligation to report transactional details on a monthly basis, together with or as a replacement of the VAT return. The most commonly implemented forms are VAT listings and a SAF-T obligation.

According to the European Commission, “VAT listings require traders to regularly - often along with the VAT return - submit to a tax administration data on received and issued invoices: Business-to-Business (B2B) transactional data.”[1] We further define VAT listings as transactional data broken down to the invoice level which excludes obligations to report transactional data broken down to the counterparty level (as in e.g. Belgium). Countries have implemented this requirement in different manners, requiring companies to e.g. include different data points on the invoices.

Another way to implement periodic reporting is via the Standard Audit File for Tax (SAF-T). SAF-T was developed by the OECD in order for businesses and accounting software to create an audit file “which is easily readable by virtue of its standardisation of layout and format”.[2] Such a file does not only contain invoice information, but also more broader accounting information. Most countries implementing periodic reporting via SAF-T implement a monthly, quarterly or yearly reporting obligation. However, there are also countries that require companies to archive their bookkeeping following SAF-T, upon which it can be requested in case of an audit (e.g. France and Luxembourg).

Table 1: Periodic Reporting throughout the European Union

Country Periodic form
Lithuania SAF-T (i.SAF)
Poland SAF-T (JPK) - mandatory real-time reporting planned 2023 to replace SAF-T
Portugal SAF-T (SAF-PT)
Romania SAF-T - Also introducing mandatory e-invoicing in the near future)
Bulgaria VAT listings
Croatia VAT listings
Czech Republic VAT listings
Estonia VAT listings
Latvia VAT listings - moving towards real-time reporting
Slovakia VAT listings - moving towards real-time reporting

Such obligations have done relatively well in terms of tackling VAT fraud. For example, Slovakia went from a VAT gap of 25% in 2015 to a VAT gap of 16% in 2019. Another success story is Portugal. Portugal was the first country in the EU to implement SAF-T in 2008 (at that moment upon request and not in a periodic manner). Subsequently Portugal implemented an obligation to send the so-called SAF-PT for invoicing on a periodic basis in 2014, while the full SAF-PT accounting files will be obligatory for periodic reporting from 2024.[3] The results of the SAF-PT for invoicing are positive, helping to reduce the VAT gap from 12.7% in 2015 to 7.9% in 2019.[4]

Periodic reporting VS. real-time reporting

Even though these EU Member States have achieved successes with these periodic reporting obligations, an increasing number still wants to move towards real-time reporting as Table 1 shows. Besides, Member States without any periodic reporting obligations implemented are often directly looking to some form of real-time reporting (e.g. Belgium[5], Germany[6] and Ireland[7]).

A first reason for this might be the challenges several countries had/are having with the implementation of, especially, SAF-T. For example, countries such as Norway[8], Poland[9], Romania[10] postponed its implementation multiple times.

Secondly, real-time reporting can be more easily integrated with existing business processes than any form of periodic reporting. With real-time reporting, invoices need to be reported at the moment of issuance (or at least within a time frame of a couple of days) which is very close to the existing invoicing process. Furthermore, only transactional data (as opposed to SAF-T accounting data) needs to be sent. This is easier for companies as they often use different software tools for invoicing than for accounting.

Third, by reporting on a daily basis the data quality is likely to increase because it forces companies to carefully assess the invoice details at the moment of issuance. When the reporting moment is only at the end of the period, it can be harder for especially smaller companies to remember or acquire the context of a transaction to validate it.

Lastly, there is a digitalisation trend to be seen in many fields of taxation and an increasing usage of real-time information. The Tax Administration 3.0 initiative of the OECD is a good example of this.[11] It is therefore only logical to also go this way for VAT reporting obligations in order to integrate real-time analyses in both government and business processes. The same move can be seen in other areas such as auditing, where real-time auditing is becoming more and more common.[12]

Towards a harmonised EU real-time reporting regime, while protecting taxpayers’ data

Recently, we discussed that the European Commission is preparing a legislative proposal in order to harmonise the wide variety of existing VAT reporting requirements. This is an excellent development that can both help tax authorities to increase their revenue and make it easier for businesses to comply with VAT legislation. Summitto can help tax authorities to implement real-time reporting in a fully confidential way. This optimally protects taxpayers' data, while at the same time offers all benefits of any other real-time reporting solution.

Conclusion

In this blog post we explained what periodic reporting is, both discussing VAT listings and SAF-T reporting obligations. Although such obligations have achieved excellent results in the past, many EU Member States are now considering real-time reporting. The main reasons are:

  • Challenges with the implementation of periodic reporting in other countries;
  • Reporting transactional data is more in line with existing company processes;
  • The data quality will be increased when companies report on a real-time basis;
  • To bring VAT reporting in line with other government/business processes that are also in real-time.

In case you want to know more about our periodic or real-time reporting solutions have a look at our website at www.summitto.com or do not hesitate to contact us at info@summitto.com

[1] https://ec.europa.eu/taxation_customs/system/files/2018-01/vat_listings_in_eu_en.pdf

[2] https://www.oecd.org/tax/forum-on-tax-administration/publications-and-products/45045602.pdf

[3] https://edicomgroup.com/blog/portugal-makes-it-mandatory-to-declare-the-saf-t-accounting-file

[4] https://op.europa.eu/en/publication-detail/-/publication/bd27de7e-5323-11ec-91ac-01aa75ed71a1/language-en/

[5] https://www.vatupdate.com/2022/02/17/scope-timeline-implementation-of-mandatory-b2b-e-invoicing-in-belgium/

[6] https://www.tagesschau.de/koalitionsvertrag-147.pdf

[7] https://home.kpmg/ie/en/home/insights/2022/01/vat-compliance-change-horizon.html

[8] https://blogg.pwc.no/skattebloggen-en/introduction-of-saf-t-in-norway-postponed-to-2020

[9] https://www.globalvatcompliance.com/globalvatnews/poland-new-saf-t-file-will-be-postponed/

[10] https://www.globalvatcompliance.com/globalvatnews/romania-saf-t-obligation-2022/

[11] https://www.oecd.org/tax/forum-on-tax-administration/publications-and-products/tax-administration-3-0-the-digital-transformation-of-tax-administration.pdf

[12] https://www.pwc.nl/nl/spotlight/assets/documents/pwc-real-time-robot-audit-2014-1-06.pdf