Tax Newsletter: Draft SAF-T legislation published
12/12/24
The Bulgarian government has published draft legislation for the introduction of mandatory submission of Standard Audit File for Tax ("SAF-T") reports. The legislation is expected to be adopted and come into force in the beginning of 2025.
You can find a summary of what has been proposed below.
What is SAF-T?
SAF-T is a structured electronic format for the submission of the detailed accounting information of a business to the revenue authorities in a standardized and machine-readable way.
Who will have to submit SAF-T reports?
SAF-T reporting will become mandatory for businesses in several waves:
- from 2026 for large enterprises with annual net revenue exceeding BGN 300 m. / EUR 153 m. or annual net tax and social security liabilities exceeding BGN 3.5 m. / EUR 1.8 m.;
- from 2027 for large, medium and small enterprises with annual net revenue exceeding BGN 300 m. / EUR 153 m. or annual net tax and social security liabilities exceeding BGN 3.5 m. / EUR 1.8 m.;
- from 2028 for large, medium and small enterprises with annual net revenue exceeding BGN 15 m. / EUR 7.7 m. or annual net tax and social security liabilities exceeding BGN 1.5 m. / EUR 0.8 m.;
- from 2029 for all large, medium and small enterprises;
- from 2030 for all VAT-registered enterprises.
The criteria for category of enterprise, annual net revenue and annual net tax and social security liabilities are assessed for two years in the past (i.e., reporting obligation will arise for 2026 if the criteria were met by the enterprise as at the end of 2023).
What information will be submitted with SAF-T?
SAF-T reports will cover detailed business and accounting information including:
- identification data for the taxpayer, including related parties and ultimate owners;
- chart of accounts and all accounting entries;
- all purchase and sales invoices, including all suppliers and customers;
- all incoming and outgoing payments;
- all assets and inventory and transactions with them;
- business nomenclatures and tax codes.
In total close to 400 separate mandatory data points will have to be reported with SAF-T (out of close to 1,000 data points in total). The Bulgarian revenue authorities have already published a draft structure of the information fields to be included in SAF-T reports.
How often will SAF-T reports have to be submitted?
SAF-T reports will have to be submitted on a monthly basis by the deadline for submission of VAT returns (14 days following the reporting month). A separate annual SAF-T report covering only assets and asset transactions will have to be submitted by the deadline for the annual corporate tax return (30 June following the reporting year). A special SAF-T report including information only about inventory and inventory movements will have to be submitted upon request of the Bulgarian revenue authorities.
For each wave the first 6 monthly SAF-T reports can be freely corrected by the deadline for submission of the seventh monthly SAF-T report. Late submission of SAF-T reports can lead to fines of between BGN 5,000 - 15,000 / EUR 2,600 - 7,700.
