Extended VAT SAF-T file (VDEK) – new requirements
From April 1, 2020, large entrepreneurs (and all others from July 1, 2020) will be required to submit monthly VAT SAF-T in a new, extended version (JPK_V7M, "VDEK"). This structure will combine data from the VAT return and VAT records / evidence.
VDEK means change in both: the structure of the xml file and new information requirements (new type of reporting data needed). Obtaining new reporting data is a key aspect - in many cases this information may not be easily accessible from the ERP system level.
VDEK – key challenges
Implementation and reporting of VDEK will require coordination and cooperation of technical teams (IT) as well as financial and tax departments. The changes resulting from the introduction of VDEK are of both technical (IT) and substantive (tax) nature. In our opinion, the key challenges related to the implementation of VDEK include:
- Limited time - the first VDEK SAF-T file will have to be submitted by large taxpayers by May 25, 2020 (reconciliation period of April 2020). This means that from April 1, taxpayers should be ready to collect and process data in a way that will allow proper preparation of the VDEK SAF-T file. Therefore, the time for implementing VDEK reporting is less than 3 months.
- New data - the data required by VDEK goes beyond the information that was previously collected for the purposes of VAT reporting (both under VAT registers and existing VAT SAF-T files). More specifically, VDEK requires specific tags for selected goods and services. In addition, identification of transactions with related entities is required. The use of mandatory split payment mechanism or the use of special taxation regimes, e.g. in the field of distance selling or the provision of electronic and telecommunications services also need to be marked.
- IT changes - the introduction of VDEK will require changes in the area of collecting and extracting data from financial and accounting systems. A common problem is the precise formulation of required changes to the system in a way that will be understandable and properly parameterized from the point of view of IT departments. Lack of understanding in communication between IT and business is one of the most common reasons for delays and errors in implementing SAF-T reporting.
- Sanctions - a number of sanctions have been introduced to ensure that the data provided in the new VDEK structure will be of adequate quality. The amended provisions of the Fiscal Penal Code and a fine of PLN 500 for each error in VDEK SAF-T file give little space for simplifications in the reporting process or errors in data extracts.
In our opinion, the efficient implementation of VDEK requires the following steps:
- assessing to what extent the new data required in VDEK will apply to the
company's situation (identification of gaps), - determining how the gaps in the scope of the required data can be closed and
where and how to obtain new data in the system (closing the gaps), - preparation of specifications for the extract of complete data for VDEK reporting
and generation of an xml file, - validation of implementation results (technical and substantive tests).
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