Headline Verdana Bold

Transcription

1 Headline Verdana Bold Deloitte Academy Seminar From e-audit files upon demand to real-time reporting. Are you ready for SAF-T? Deloitte Belastingconsulenten/Conseils Fiscaux

2 Before we start Please turn off your mobile phone and laptop

3 Agenda Topic Content Presenter Timing Welcome & Registration (sandwich lunch) Introduction Global Trend on Tax Transparency, audit and data Frederik 13:00 p.m. 13:15 p.m. Current evolutions in EMEA From e-audit to Real-Time Reporting Pieter 13:15 p.m. 13:45 p.m. Addressing the Challenges Technology, Process and Data Pieter 13:45 p.m. 14:00 p.m. Break Process Support Solution Approach Pieter 14:15 p.m. 14:45 p.m. Demo (Disruptive) Technology Update Sample Case: Blockchain Frederik 14:45 p.m. 15:15 p.m. Final Conclusions Conclusion and next steps Liesbet 15:15 p.m. 15:30 p.m Deloitte Belgium Deloitte Academy Seminar SAF-T 3

4 Introduction 2016 Deloitte Belgium Deloitte Academy Seminar SAF-T 4

5 Introduction Setting the scene A variety of forces are combining to change the world of compliance: financial pressure on governments to focus on tax take public focus on transparency from corporate taxpayers This has resulted in a variety of new laws and efforts at national and international level Tax environment now focussed on transparency and data 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 5

6 Digital Tax is growing fast (some examples) Countries worldwide are adopting new ways of monitoring, many of these are Digital: Digital Tax Policy VAT rules in digital economy e-commerce and MOSS Cross-Border collaboration, information sharing and joint audits. Legal disclosure and approval (local) Netherlands: Horizontal Monitoring UK: SAO Electronic invoice disclosure and required e-invoicing Belgium: B2G France: B2G Italy: B2G Spain: SII Brazil: SPED China: Golden Tax System Legal initiatives e.g. Country-by- Country Reporting (Global) OECD Countries Electronic disclosure of VAT Ledgers Poland Czech Republic Electronic Audits and SAF-T Norway Lithuania: isap Germany: GDPdU Poland: JPK France: FEC Luxembourg: FAIA Modernization of tax authorities and audit procedures. UK: Making tax Digital 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 6

7 Digital Tax is growing fast Different ways of Electronic Audits Next: Blockchain? Electronic audit files Ad hoc Format Standardized Electronic audit files Structured Format OECD SAF-T Elements Standardized Electronic Transactions and Ledgers Structured Format OECD SAF-T Elements Detailed line level Distributed/Shared Data Immutable Records and audit trail. Digital technologies allow for more data to become available. The level of detail and the variety of data is increasing. Authorities explore use of sophisticated, and cognitive technologies to use tax data. End-to-end transparency is anticipated with the introduction of new disruptive technologies such as Blockchain. Upon Request Upon Request Periodic and (Near) Real-Time Data Frequency and Format 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 7

8 From eaudit to Real-Time Reporting 2016 Deloitte Belgium Deloitte Academy Seminar SAF-T 8

9 eaudit upon demand Example: Belgium Data Requested Lead Time Typical Activities SAP ERP Tables for FY2016 Financial/Tax Posting Master Data Customers/Suppliers Accounts/Cost centers Tax codes 1 month for data extraction +1 month, after additional information requested from the inspector Classic audit support Analyze and reconcile data, find underlying documents and off system information Prepare for questions and responses 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 9

10 SAF-T upon demand Example: France Data Requested Lead Time Typical Activities Fichier d Écriture Comptable (FEC) On-site: 1st meeting Off-site: 15 working days Assistance on the preparation (format) and testing of the FEC file (content) Pro-active validations In advance 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 10

11 SAF-T Periodical Example: Poland Data Requested Lead Time Typical Activities JPK_VAT - VAT sales & purchase register Monthly Assistance in the preparation and filing of the reporting Embedded in compliance process Challenge : link with compliance process (to reconcile) + shorter lead-time 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 11

12 Real-time reporting Example: Brazil Data Requested Lead Time Typical Activities Sales invoices Real-time Set up of the process Embedded in the sales and supply chain process Involvement in IT infrastructures 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 12

13 Real-time reporting Brazil: Invoice Flow Invoice 3 Taxpayer 2 4 Client 1 Tax Administration 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 13

14 SAF-T: Introduction 2016 Deloitte Belgium Deloitte Academy Seminar SAF-T 14

15 SAF-T: Introduction Europe: Standard Audit File for Tax (SAF-T) SAF-T has been designed to capture data from a number of areas found in a typical business accounting system Periodically per legal entity Master data Balances Transaction Across taxes, including info relating to VAT CIT Transfer pricing General ledger Journals Accounts Payable Supplier master data Invoices Payments Accounts Receivable Customer master data Invoices Payments Fixed assets Asset Master Files Depreciation and revaluation Inventory Product master data Movements 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 15

16 The move towards Electronic Audits The changing face of tax compliance From taxpayers information systems to authorities audit software Yesterday Manual keying of data Slow and uncertain transmission of returns Risk of loss of documents and penalties Sample-based approach for audits Today Automatic or semi automatic keying of data Automatic production of reporting documents Some e-filing/cross checking of information Direct audits of ERP systems/ accounting software Need to update IT systems Tomorrow (already today?) New form of automatic controls In theory faster, surer, more precise, more efficient Issue: Need for standardized documents for taxpayers IT systems Death of the tax return? Today Safe transmission of data Automatic consistency checks performed Incontestable proof of filing General lack of consistency in testing/filing of data Slight country variations in format and requirements Production of compliant standard data 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 16

17 SAF-T: upon request 2016 Deloitte Belgium Deloitte Academy Seminar SAF-T 17

18 SAF-T: upon request Country Legal ent. Non-est. VAT reg. Comments Austria France All VAT registered companies and branches. Germany Lithuania Luxemburg Exceptions: - Taxpayers exempt from Standard Chart of Accounts ("PCN") obligation - Taxpayers subject to the simplified VAT return regime - Taxable turnover whose annual turnover is below ,00 EUR - Small taxpayers with few transactions (+-500) so that manual check is easier than submission of an electronic file Deloitte Belgium Deloitte Academy Seminar SAF-T 18

19 SAF-T: upon request Country Legal ent. Non-est. VAT reg. Comments Netherlands All companies currently liable to maintain book-keeping information electronically. Norway Exceptions: (1) Companies with VOES registrations in Norway (2) Companies with turnover of less than 5 Million NOK (3) Companies with less than 600 vouchers a year Companies liable to keep books that are covered by the exceptions (2) and (3), but have bookkeeping information available electronically, are still covered by the SAFT requirement. Poland -JPK_KR (Accounting books) -JPK_WB (Bank account statement) -JPK_MAG (Warehouse) -JPK_FA (Invoices) -JPK_PKPIR (Revenue and expense ledger) -JPK_EWP (Revenue registry) Portugal Companies subject to Corporate Income Tax 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 19

20 SAF-T: periodical 2016 Deloitte Belgium Deloitte Academy Seminar SAF-T 20

21 SAF-T periodical Country Legal ent. Non-est. VAT reg. Comments Czech Republic VAT Control Statement Lithuania i.saf : VAT records i.vaz, data relating to goods consignment/transport Portugal Companies subject to Corporate Income Tax Poland JPK_VAT, VAT sales and purchase register Slovakia VAT Control Statement 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 21

22 Real-time reporting 2016 Deloitte Belgium Deloitte Academy Seminar SAF-T 22

23 Real-time reporting Country Requirement Legal ent. Non-est. VAT reg. Comments France Electronic reporting for all sales with VAT Law has been declared unconstitutional because the fine for non-compliance was considered disproportionate. Hungary Electronic reporting of all B2B sales invoices with VAT above HUF100,000. (From 1 July 2018) Businesses will receive in return from the tax authorities a unique invoice number that they must include on the invoice prior to issuance to their customers. The maximum fine for failing to comply with the new rules will be up to HUF500,000 per invoice. Poland Daily reporting of JPK_WB (Bank account statement) (From 1 Sept 2017) No other details yet. early stage / an idea to cross check payments with supplies. Lots of resistance from business and financial sector, so it is uncertain if it will go ahead Spain Electronic reporting for all sales with VAT (From 1 July 2017) SII Suministro Inmediato de Información 4 day timeframe as of the moment they issue or receive them (deadline extended to 8 working days between July 1st, and December 31 st 2017) 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 23

24 Spain Suministro Immediato de Informacion Real-time reporting requirements The requirement is to submit invoice records, plus certain additional information, not the invoices themselves The regulations apply to large businesses ( 6M turnover), those in a refund regime and VAT groups. Taxpayers can also optionally adopt The introduction of the SII regime removes the requirement to submit the monthly, quarterly and annual informative declarations returns (the Modelo 347, 340 and 390), not the VAT returns themselves that would still need to be filed The regulations apply to both invoices issued and invoices received. Different XMLs for invoices issued/received, capital goods, Intra-EU movements; payments in cash The timing of submission is eight days after issuance for 2017, and reduces to four days in 2018 For AR, this is from invoice issuance date For AP, this is from the date the invoice is accounted The tax authority will have a web portal for manual submission, where there are minimal transactions There will be a web service, which can integrate larger volume of invoice records this could be bolted on to the ERP, or used as an XML import tool (either manually or through third parties) There will be some cross-validation of data by the Tax Authority of the invoice records 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 24

25 Spain Suministro Immediato de Informacion Compliance impacts Submission contents Content of filings is not the same as the current purchase books new reports will be required Submission deadlines (tending to daily filings) Descriptions are not standardized, but should not conflict with the VAT rate provided Recoverable tax amount reported for each invoice partial exemption adjustments? Impact to other Special Schemes (TOMS)? Employee reimbursements report against employee or underlying supplier? Retroactive reporting solution required The regulation is effective from 1 July 2017 but also note that during July December 2017, there is a requirement to retroactively submit all invoice records from 1 January 2017 to 30 June 2017 Non-ERP based transactions (e.g., intercompany invoices, retail systems, etc.) how do these consolidate into the SII submission? Timing of reporting of transactions, submission deadlines (daily submissions) Submission and audit processes ERP data External data Consolidate and validate data Web portal Tax Authority database Audit process 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 25

26 Spain Suministro Immediato de Informacion Key items New obligations on transactions recording The new Anticipated Electronic VAT Reporting System (SII) entails the electronic supply, through the Spanish Tax Authorities on-line platform, of billing registries which are part of the VAT ledgers Deadline to submit the information Issued invoices: Four days from its issuance. If its issued by the recipient or a third party, eight days. Anyway, always before the 16 th day of the following month from the accrual date Received invoices: Four days from its accounting. Always, before the 16 th day of the following month from the accrual date Imports: Four days from the date in which the accounting document (in which the VAT quota is indicated) was registered. Always, before the 16 th of the following month from the accrual date Saturdays, Sundays and national holidays are excluded from counting Temporary period: (1 July 31 December 2017) deadline is extended from four to eight days Billing by a third party: Eight days Key issues Dates of implementation Entry intro force by 1 July However, the VAT ledgers covering the first half of 2017 must be submitted before 1 January 2018 Mandatory for large entities, VAT grouping, and companies included in the Monthly VAT Refund Registry -REDEME- ( taxpayers more or less = 80% of VAT revenues in Spain) Optional for taxpayers who voluntarily want to enroll the system, by submitting the corresponding census form Ways of submission On-going basis through a web service from the Spanish Tax Authorities on-line platform Taxpayers with few operations could report the information through a web form 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 26

27 Challenges 2016 Deloitte Belgium Deloitte Academy Seminar SAF-T 27

28 Challenges Challenges driven by the tax authority Short implementation time Requirements not/limited available in local language Tax inspector cannot bring clarity/lack of experience Challenges driven by the company Process Indirect direct statutory accounting process Local COA Out of book adjustments Opening balance/closing balance bookings Reconcile with compliance process 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 28

29 Challenges Technology ERP landscape Underlying sub systems How to extract How to validate How to generate compliant files How to communicate towards tax authorities Data Which data to extract Where to extract from Master Data completeness How to reformat data / fixed values 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 29

30 Break 2016 Deloitte Belgium Deloitte Academy Seminar SAF-T 30

31 eaudit: different ways to get prepared 2016 Deloitte Belgium Deloitte Academy Seminar SAF-T 31

32 eaudit: upon demand or periodical Country-by-country or a strategy Spain Spain Portugal Poland Belgium Poland Portugal 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 32

33 Country-by-country Country specific Data Model Knowledge Spain Per jurisdiction, the specific data model is linked to the e-process E-requirements per country: What can be requested/when Indirect vs direct tax Penalties for non compliance Overview of data fields Overview of data format Matching with overall structured data model Poland Portugal Country data models often captures info from General Ledger Accounts Receivable Accounts Payable Fixed Assets Inventory eaudit Process 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 33

34 Strategic approach Spain Overall Corporate Data Model Knowledge Structured data model is based on the OECD SAF-T model. E-requirements per country: What can be requested/when Indirect vs direct tax Penalties for non compliance Overview of data fields Overview of data format Matching with overall structured data model Poland Portugal Belgium Data model captures info from General Ledger Accounts Receivable Accounts Payable Fixed Assets Inventory eaudit Process 1 time analyze phase Applicable to countries where no SAF-T is yet in place Prepared for change upfront Risk & opportunity drivers can be applied 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 34

35 eaudit: Dashboard Demo 2016 Deloitte Belgium Deloitte Academy Seminar SAF-T 35

36 Real-time reporting process Example for Spain 3. SII XML file ERP SII convertor/ generator Communication platform 4. SII XML response Spanish Tax Administration 1. Raw SII Data SII Communication process & error handling FTP Server 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 36

37 Technology Update 2016 Deloitte Belgium Deloitte Academy Seminar SAF-T 37

38 Exponential technologies Tax Analytics Implications Exponential technology is already disrupting the work of tax professionals At simplest level automation reduces the amount of mundane/repetitive task Exponential technologies contribute to an increase in the availability of data, which in turn drive more sophisticated analytic approaches Cognitive technologies can help analyse legislation, or help extract/categorise tax data from underlying sources Scope for cognitive and analytics technologies to interact provides valuable predictive knowledge searches on tax technical issues 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 38

39 Connected world Overview Interoperability of services and data is ever more important in the tax world Both tax authorities and commercial enterprises are embracing APIs (application programming interfaces) to better serve clients We are now seeing the advent of Digital Government where interfaces enable data exchange in support of various government services There is future potential for corporate to leverage APIs as well as explore Blockchain as a means to maintain and demonstrate the reliability of shared data 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 39

40 Blockchain as a system More than crypto-currencies, Blockchains have multiple applications As a Currency Systems native currencies (e.g., Bitcoin, XRP) Measures the market value of goods and services Intermediates the exchange of goods and services Can be reliably saved and retrieved as store of value Blockchain System As a System Systems network (e.g., Blockchain, the Ripple Network) Enables efficient transfer of value and information Immutability of the system guarantees high-fidelity Allows for programmability Each application serves as the foundation for more sophisticated uses Smart Contracts Program protocols to execute transactions when a set of pre-determined conditions are met Transfer of Value Enable low-cost, near real-time value transfer without an intermediary Expand to transfer of other assets beyond money Record Keeping Create an immutable record without reliance on a trusted third party Improve efficiency of record keeping via automation Greater sophistication Digital cheques / IOUs Automatic financial instruments Parametric insurance contracts Automated market making Examples Domestic and international remittance Internal payments settlement Clearing and settlement of securities Exchange of low liquidity assets Digital certificate of ownership for physical assets Transaction validation of digital assets Financial accounts 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 40

41 Vat automation in the Digital Supply Chain Example for Physical Supply of Goods Example High Level overview of a system using electronic messaging with shipment approval and confirmation Approval Approval Code e-invoice Paper Invoice 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 41

42 VAT and Blockchain Possible Blockchain applications? 1. Each transaction consists of one block. 2. Mutual agreement on content of the block. 3. Each Block is added to the chain to form a distributed ledger. 20 Message VAT N Taxable amount and VAT Description good/service Etc. 20 Blockchain Bank transfer Deloitte Belgium Deloitte Academy Seminar SAF-T 42

43 Some Design thinking to your ERP How to prepare ERP systems will continue to remain a backbone solution, driven by a legacy of master data and process standardization. However needs connectivity and integration with a growing eco-system of applications both internal and external Faster: From ad-hoc to monthly and real-time. Immediate response required! Invoice and Document Management. Integration management. Better: Eliminate error prone process and manual interventions Tax sensitive process should be touchless Tax Reporting and Automation Data and Process Analytics. Controlled: Measure and Monitor change and deviations Full transparency Business Process and Activity monitoring. Process orchestration, full end-to-end integration No Mistakes allowed Deloitte Belgium Deloitte Academy Seminar SAF-T 43

44 Final Conclusions 2016 Deloitte Belgium Deloitte Academy Seminar SAF-T 44

45 Final Conclusions Key Messages Tax authorities are going Digital in a response to combat fraud and to increase fairness and efficiency in revenue collections. SAF-T is one example but you need to respond fast. Technology is the tool, Data is the Fuel The availability of digital tax data is not determined by the existence of a predefined format. It is a business process produce and an ERP system s legacy. Tax, Business and IT Alignment It assumes alignment, formalization and standardization in business processes far beyond your tax function Deloitte Belgium Deloitte Academy Seminar SAF-T 45

46 Final Conclusions Next Steps 1 Get a view on your process and data quality Where are the gaps? 2 Get connected. take the lead and ensure external regulatory requirements are in line and with the internal organization. This includes the business and IT Deloitte Belgium Deloitte Academy Seminar SAF-T 46

47 Contact Information Liesbet Nevelsteen Partner, Indirect Tax Work : Mobile : Pieter Van Dyck Senior Manager, Tax Management Consulting pivandyck@deloitte.com Work: Mobile: Frederik Drappier Senior Manager, Indirect Tax fdrappier@deloitte.com Work: Mobile: Deloitte Belgium Deloitte Academy Seminar SAF-T 47

48 Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee ( DTTL ), its network of member firms, and their related entities. DTTL and each of its member firms are legally separate and independent entities. DTTL (also referred to as Deloitte Global ) does not provide services to clients. Please see for a more detailed description of DTTL and its member firms. Deloitte provides audit, tax and legal, consulting, and financial advisory services to public and private clients spanning multiple industries. With a globally connected network of member firms in more than 150 countries, Deloitte brings world-class capabilities and high-quality service to clients, delivering the insights they need to address their most complex business challenges. Deloitte has in the region of 225,000 professionals, all committed to becoming the standard of excellence. This publication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms, or their related entities (collectively, the Deloitte Network ) is, by means of this publication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte Network shall be responsible for any loss whatsoever sustained by any person who relies on this publication Deloitte Belgium

49 Annex 2016 Deloitte Belgium Deloitte Academy Seminar SAF-T 49

50 eaudit Process Analysis Data Extraction Data Validation Data Reconciliation Corrections Assembly 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 50

51 Aanalysis Analysis of the technical Set up & Processes Review of the current compliance processes Statutory process Direct tax process Indirect tax process Review significant Business event for the period Review Accounting systems landscape Review tax audit history Define country by country approach or structured data model 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 51

52 Data Extraction Extract the tax relevant data from the different source systems identified during the analysis Which date should be extracted depends on whether are structured date model is put in place or a country by country approach is implemented Based on the outcome of the analysis, different data might need to be extracted from different source systems (main ERP, legacy systems, billing systems.) Extracted data should be transferred to a data platform (data warehouse / data mining tool) for further handling in the next phases. Potential Technologies SAP DART TJC SNI SAP OSS Notes Data Warehouse 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 52

53 Data Validation Extracted data should be validated prior to the assembly of the eaudit file Data Completeness Data Consistency Potential Technologies Records Master Data Company Code Fiscal Year Transactions Lines Vendors/Customers Tax Codes Data Mining Tools: Caseware IDEA ACL Analytics Customized Data Warehouse Queries 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 53

54 Data Reconciliation The extracted data should reconcile official filings Automated Data Pool Filings Not Automated: Sample testing Criteria: - Fiscal Year - Business Events - Size - Etc Deloitte Belgium Deloitte Academy Seminar SAF-T 54

55 Assembly Assemble the extracted data into an eaudit file according to the local requirements Different file formats (csv, xml, ) Per jurisdiction the file structure varies Local required default values can be expected e.g. Portugal movement type = GR = Delivery note GT = Transport guide GA = Transport document for own fixed assets GC = Consignment note GD = Return note TJC SNI Potential Technologies SAP OSS Notes Data warehouse queries Data Mining Tools: Caseware IDEA ACL Analytics 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 55

56 Process Real-time vs upon demand/periodical The same process applies but in real time reporting there are additional challenges Less preparation time No manual intervention eaudit process should be linked as close as possible to where the correct data is stored Automated communication protocol/platform End-to-end automated processes 2017 Deloitte Belgium Deloitte Academy Seminar SAF-T 56