Beginning January 1, 2023, average taxpayers will be required to file a Standard Audit File (SAF-T), also known as a 406 statement.

However, ANAS has not updated the list of average taxpayers since 2016. The institution prepared an order to extend the deadline for updating the lists of large taxpayers, including their secondary divisions, until December 10, 2023.

Average taxpayers and the SAF-T project– click to open

Draft order SAF-T annex – click to open

In this order, we understand that there will be no extension of time for filing the SAF-T. Therefore, from January 1, 2023, it will have to be submitted by middle peasants.

In addition, the number of average taxpayers to be administered through the existing specialized structures at the level of district public finance offices and, accordingly, the tax administration for average taxpayers, has been changed from 18,478 at present to 15,000 taxpayers selected in descending order of the base criteria approved by the order of 2016 (3610/2016)

At the same time, the project provides for the elimination of the criterion of fiscal representation, on the one hand, due to the reduction of the contribution of these taxpayers to the total amount of collected budget revenues, and on the other hand, the application of the unitary principle in relation to the selection criteria of average taxpayers.

According to the Evidence Report, due to this reduction in the number of medium taxpayers, the tax liabilities declared by large and medium taxpayers were considered to be representative, respectively 65.61% of the total liabilities declared nationally in 2021 .

Other changes:

As certain taxpayers classified as average taxpayers as at 31 December 2021 will no longer be in that category on 1 January 2023, it is proposed that they no longer need to file information return D406 from the reference date for average taxpayers taxes, become mandatory from the reference date for small taxpayers.

Taxpayers who have chosen to submit the information declaration D406 will not be able to withdraw from the expressed option in the future. The option will come into force after the submission of the information declaration D406, confirmed by the DPAU.

It is also proposed that for taxpayers classified as small taxpayers as of December 31, 2021, who retained this classification during 2022, and from January 1, 2023, classified as medium taxpayers, the submission of information return D406 should become mandatory, starting from the reference date for average taxpayers, the rationale is that from 1 January 2023 all average taxpayers must file information return D406 without any difference in the regime between them.

ANAF President Lucian Heyusch recently said that SAF-T will be a big challenge next year when mid-level taxpayers start submitting it.”

“There will be mistakes next year as well. We will not sanction the error. On the contrary, we will appreciate someone who, even if he submits with errors, submits and makes an effort to report,” he also showed.

He also said, “Don’t ask me if I’m procrastinating. I’m not a big fan of extensions. If I postpone something, I stay for another six months.”