Questions and answers - SAF-T Financial
SAF-T is a standard format for the exchange of accounting data. The standard is the result of a joint development collaboration between the business communicty, the accounting sector and the Norwegian Tax Administration, based on a recommendation by the OECD. The standard specifies what accounting data is to be exchanged, and also the structure of the data.
For businesses with bookkeeping obligations, it will be easier to submit accounting records to public authorities. It will also be easier to perform internal audits in companies, analyse data in specialised systems and share data with others. In addition, it will be easy to change accounting system and to integrate different systems. For the Norwegian Tax Administration, the new way of collecting accounting data means more efficient audits and shorter case-handling times as a consequence of automation and fewer manual processes
The requirement will be applicable to any enterprise with bookkeeping obligations who use electronical accounting systems. Enterprises with less than NOK 5 million in turnover are exempt from the requirement. However, if these enterprises have bookkeping information that are electronically available, the requirement will apply to them. It is the system suppliers who must adapt their accounting systems so that the systems can provide the new standard on demand. Enterprises with a bookkeeping obligation who have fewer than 600 vouchers a year, and hold their accounts in a text editor or spreadsheet programs are not included in the requirement, because these systems are counted as manual solutions and not an electronical accounting system, ref. NBS 6 section 4.
No, accounting information in this format does not replace tax return reporting, but must be made available to the tax office in connection with a tax audit on request by a tax auditor.
The regulation comes into force the first period with financial reporting starting 1. januar 2020 or later. Until then the use of the SAF-T scheme will be voluntary.
There will not be a transitional arrangement like there was for cash register systems.
There is no requirement to show transactions retrospectively. The accounting systems will most likely be able to generate SAF-T files for earlier periods if these are in the same database and in the same format as transactions after 1 January 2020.
If the accounting system is supposed to be used to produce SAF-T files, this is something the system developers have to manage in the development of their accounting systems. Norwegian suppliers of accounting systems have been involved in a dialogue since autumn 2015, and some of them were also involved in developing the standard itself.
However, there may occur divergent use of accounts or vat codes, which results is an obligation for the accountant or the enterprise with a bookkeeping obligation to ensure that the mapping is complete.
The first version of the standard was ready in March 2016 and it is published on skatteetaten.no. The first version is limited to account specification (general ledger), and supplier and customer specification (subsidiary ledger). Required fixed data is also included.
As long as a business has bookkeeping information in an electronic format, it will be required to show recorded information in SAF-T format. This means that banks are required to use the format in the same way as other businesses that are required to keep accounts. Public sector companies are also subject to this requirement if they have bookkeeping obligations.
The first version of the standard does not have any fields for consolidated financial statements. This will be a feature in later versions.
Yes, as of September 2016, system suppliers were given the opportunity to test their solutions. The Norwegian Tax Administration recommends that all system suppliers perform testing.
Uploading via Altinn is the main method for submitting SAF-T files for those with an accounting obligation. If you have large files of more than 200 MB (or more than 2 GB by ZIP file) you can contact your case officer.
The detailed requirements concerning the account specification and customer and supplier specifications are provided in section 3-1, subsection 1, no. 2, 3 and 4 of the Bookkeeping Regulation. All entries must be presented in the appropriate order with documentation date and documentation reference. The account specification and customer and supplier specifications are comprised by the SAF-T requirement. Items may be presented as totals, provided that transactions and other accounting entries are specified individually and added up in underlying specifications, and are verifiable against the totals, see the Bookkeeping Regulation, section 3-1, subsection 5. However, this does not apply to items in customer and supplier specifications.
If the recorded information is kept in a preprocessing system, the preprocessing system becomes part of the accounting system, and the recorded information in the preprocessing system must be kept available online for 3.5 years after the end of the accounting year. An example can be that the customer specification is entered in the invoice system, while the account for receivables in the account specification only shows aggregated numbers (per month, updating period, etc.). In such cases, documentation date, documentation reference, customer code, amount, etc. for each individual transaction only exists in the invoice system that constitutes a sub-specification to the account specification.
Sub-specifications are considered part of the account specification and are comprised by the SAF-T requirement. Customer and supplier specifications entered in a preprocessing system are comprised by the SAF-T requirement.
Section 7-8 of the Bookkeeping Regulation and the requirement for transferring accounting data in the SAF-T format is only applicable in an audit situation. Stating the customer’s name and address or organisation number is obligatory information when preparing sales documents, see the Bookkeeping Regulation sections 5-1-1 and 5-1-2. The customer’s code and name must be specified in the customer specification, see section 3-1, subsection 1, no. 3 of the Bookkeeping Regulation. In other words, the SAF-T file can include personal data.
The Tax Administration processes personal data in connection with carrying out statutory tasks. In these cases, the legal basis is anchored in the Norwegian Tax Administration’s special laws, such as section 10-2 of the Tax Administration Act. The regulation’s condition concerning the grounds for processing is therefore met.
When submitting accounting data via SAF-T, a unique identification of the taxpayers is required, such as an organisation number, a Norwegian national identity number, a D number or another available unique identifier. Using a unique identifier is necessary to ensure a correct connection between the reported information and the taxpayer. The use of a unique identifier supports the fundamental consideration of personal information protection, contributes to increased data quality, and generally ensures an efficient public administration.
For financial enterprises, insurance companies and pension enterprises with a duty to acquire a licence from the Financial Supervisory Authority of Norway, and that apply the special rules in sections 8-13 and 8-14 of the Bookkeeping Regulation, customer and supplier transactions that are linked to an account can appear as totals per accounting period in the account specification. In other words, it is not a requirement for the SAF-T file to include each individual transaction from the professional system. In the event of a control, the customer and supplier transactions linked to an account may need to be documented in another way according to an agreement with the Norwegian Tax Administration. See page 28 in the SAF-T documentation.
Ordinary customer and supplier transactions not linked to an account for the financial enterprise’s core business do not fall under the exception and must be included in the SAF-T file. This applies even if the ordinary customer and supplier transactions are put in the same professional system as customer and supplier transactions linked to an account.
The obligation to be able to reproduce electronically recorded information in standardised form from 1 January 2020 is stated in section 7-8 of the Bookkeeping Regulation and the Directorate of Taxes’ standard for content and format for the reproduction of electronically recorded information from 23 March 2018, and is directly linked to the bookkeeping obligation.
The bookkeeping obligation is stated in section 2, subsections 1 and 2, of the Bookkeeping Act (unofficial English translation):
Anyone defined as a reporting entity in Act of 17 July 1998 No. 56 relating to Annual Accounts, etc., shall be defined as a bookkeeping entity for purposes of the present Act.
Any legal or natural person that pursues business activities and is required to file a tax return in respect of wealth and income tax, etc., pursuant to § 8-2 of the Tax Administration Act shall be defined as a bookkeeping entity for purposes of the present Act with regard to the activities pursued. The same applies to any legal or natural person required to file a tax return in respect of Value Added Tax pursuant to § 8-3 of the Tax Administration Act. However, this shall not apply to providers that file a tax return in respect of Value Added Tax as mentioned in § 8-3, first paragraph, letter e, of the Tax Administration Act, and that would be defined as a bookkeeping entity exclusively on the basis of their obligation to file a tax return pursuant to the present provision.
NUF/branches that are liable for tax have an accounting duty pursuant to section 1-2, subsection 1, no. 13 of the Accounting Act, and consequently have a bookkeeping obligation in accordance with section 2, subsection 1 of the Bookkeeping Act. NUF/branches that are not liable for tax may still be subject to the bookkeeping obligation if they are registered in the Value Added Tax Register, see section 2, subsection 2 of the Bookkeeping Act.
There are no special exceptions for foreign branches with regard to the SAF-T requirement. The requirement nevertheless only applies to the entity with a bookkeeping obligation, i.e., the Norwegian branch.
The structure <CompanyStructure> to be used to enter customer and supplier information contains mandatory fields for <PostalCode> and <City>.
If this information is not available for the customers and suppliers found in the customer and supplier specifications (subsidiary ledgers), you may enter “NotAvailable” or the abbreviation “NA” or “N/A” in these fields. In this case, it is not necessary to apply and receive approval from the Tax Administration as described on page 30 in the general documentation.
It should be noted that if the addresses are registered in the system, they must be included in the SAF-T file. Please note that the address information fields must not be left blank, as this will cause the file to not validate upon submission to Altinn.
Question/answer number 17 looks at the SAF-T requirements for financial enterprises, insurance companies and pension enterprises. It is apparent that it is the enterprise that is subject to a duty to acquire a license from the Financial Supervisory Authority and that uses the special rules in sections 8-13 and 8-14 of the Bookkeeping Regulation that can use the exception that is stated on page 28 of the SAF-T documentation. Internal banks that are not subject to a duty to acquire a license fall outside of the scope of sections 8-13 and 8-14 of the Bookkeeping Regulations, and cannot therefore use this exception. This has been confirmed by the Ministry of Finance.
For most industries where only a few different percentage rates are used when calculating proportionate deductions for VAT, the use of <BaseRate> will solve the issue. However, some industries, including the real estate development industry, will often use many different percentage rates throughout the year, which means <BaseRate> is not suited for the purpose. The SAF-T export must reflect the accounts, and enterprises are not meant to construct solutions in order to adapt to a SAF-T export. The accounts are written to the SAF-T file in the same way as the proportionate deductions for VAT are processed in the accounts. It’s assumed that the method used by an enterprise when registering proportionate deductions for VAT in the accounts satisfies current legal requirements."