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Public Romania Author: Kristina Dosen
The absolute novelty here is that the new entrants to the list of large taxpayers will have to submit the first Declaration 406 by January 31st, 2023. More details are as follows.
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Content accuracy validation date: 19.11.2021
Content accuracy validation time: 09:13h

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With the publication of Order 1783 "on the nature of the information that the taxpayer must declare through the standard tax control file, the reporting model, the procedure and conditions of transmission, as well as the transmission terms and the date/ data from which the categories of taxpayers/ payers are obliged to submit the standard tax control file" by ANAF, the reporting data of the Standard Fiscal Control File (SAF-T) – so-called Declaration 406, for all categories of taxpayers, have finally been completed.

The absolute novelty here is that the new entrants to the list of large taxpayers will have to submit the first Declaration 406 by January 31st, 2023.

The Order establishes that the 1801 new companies included in the list of large taxpayers, published by ANAF at the end of last week (which brings together a total of 3,364 companies) will have the obligation to report the Standard File of Fiscal Control (SAF-T) starting with July 1st, 2022. They will also benefit from the grace period, so the first submission of Declaration 406 must be made by January 31st, 2023.

The companies that have been maintained by ANAF on the new list (about 1,576) will have the obligation to report according to the previously announced schedule, i.e. starting with January 1st, 2022, and they will also benefit from the grace period, which means that their first report will have to be submitted by July 31st, 2022.

According to the Order, the grace period is six months for the first report, respectively five months for the second reporting, four months for the third reporting, three months for the fourth reporting, two months for the fifth reporting, for taxpayers who should submit the SAF-T file monthly. In the case of taxpayers who should submit the Declaration 406 quarterly, the grace period is three months for the first reporting (therefore until 31st of December 2022).

Companies classified in the category of large taxpayers at the end of December 2021, but those that are no longer on the new list – 1369 economic agents, would submit the declaration according to the schedule established for the category of taxpayers in which they will be employed – which is either January 1st, 2023 for medium taxpayers or January 1st, 2025 for small taxpayers.

The order also clarifies the declaration deadlines that those taxpayers who, for various reasons, will have in the future leave the category from which they were classified or, on the contrary, are newly enrolled– if they make an investment of over ten million euros (the investment criteria) for example.

Also, from the SAF-T implementations started, we can say that the most important difficulties in implementing the new declaration come from the companies' misunderstanding of the reporting requirements and how they must be carried out, as well as from the identification of the source of the data required by ANAF. Therefore, we recommend the companies nominated on the list of large taxpayers to start the necessary steps to successfully start the implementation of the new Declaration.

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