As of 1 January 2020, it’s required that entities subject to a bookkeeping obligation with accounting information available in electronic format (pursuant to the Bookkeeping Act, section 13b) must present this information in a standardised format pursuant to the Bookkeeping Regulation section 7-8, subsection 1. This requirement also applies to other entities subject to a bookkeeping obligation that fall under the exceptions listed in section 7-7, subsection 3, and that have accounting information available in electronic format. On 23 March 2017, the Norwegian Directorate of Taxes has determined the Standard for content and format for the exchange of electronic accounting data. Section 7-8 of the Bookkeeping Regulation was added to the Regulation of 22 December 2017 no. 2387 with effect for the accounting period starting 1 January 2020 or later.
There is a provision in section 7-8, subsection 3, for an exception from the requirement of SAF-T accounting, including a postponement in fulfilling the requirement. It follows from the wording in section 7-8, subsection 3, that the scope for the exemption is limited to special circumstances. This, as well as a “transition period” of two years from the regulation’s requirement for SAF-T accounting, adopted for the entry into force of the provision, indicates a restrictive dispensation practice.
In processing applications for time-limited dispensation from the requirement for SAF-T accounting, the Tax Administration places emphasis on circumstances that fall outside of the entities’ control. An example could be where an entity subject to a bookkeeping obligation has entered into a contract with a system supplier well before 1 January 2020 for the delivery of SAF-T accounting functionality within the year-end, but where the supplier fails to deliver on time. The entity must either change suppliers or wait for the supplier to deliver the SAF-T functionality. Both alternatives can result in the entity being unable to fulfil their requirements within 1 January 2020, and having to apply for a time-limited dispensation. Delays between the system supplier and the entity is a civil law condition which is normally not given weight when processing an application for dispensation. In the application, it is therefore important to provide information on when the work started and was scheduled to be completed. Time-limited dispensation is granted when there is an agreed upon delivery in good time before 1 January 2020, but where the supplier has been delayed due to unforeseen circumstances. Time-limited dispensation for a period as long as one year can only be granted in exceptional circumstances. Applications for periods exceeding one year have been denied. Applications based on future possible or unclarified conditions have also been denied. Emphasis is placed only on actual circumstances that can be documented.
Applications for permanent dispensation because the system is so old that a SAF-T export function cannot be established, or that it is expensive to establish a SAF-T export function, do not provide the basis for dispensation.
If it is decided in 2019 that an enterprise will be wound up in 2020, this could be a factor that indicates that a dispensation may be granted. The Directorate of Taxes is aware that there are external suppliers in the Norwegian market that convert SAF-T accounting files from most known formats, including image files. It is possible to obtain bookkeeping information in SAF-T format, even if the accounting system does not support such an export function. This will be a factor in the assessment of whether to grant dispensation.
Applications for dispensation must contain the following information:
- The grounds for the application, including information on when the work started and was scheduled to be completed, and which events/circumstances arose along the way.
- New and updated work plan with a timeline for when the work is scheduled to be completed.
- The grounds for the application, including information on why the requirements for SAF-T accounting cannot be met.
Please send the application electronically via Altinn or by post to the tax office:
Postboks 9200, Grønland