Skip to main content
Request for proposal

      SAF-T UA is the Ukrainian model of the Standard Audit File for Tax, the international standard unified structure for exchanging accounting data with the tax authorities. SAF-T exports data from a company’s accounting system regarding the presence and condition of assets, equity, liabilities, as well as information on any changes in the financial and business condition of the company.

      SAF-T UA was developed in line with the OECD Recommendations on the Standard Audit File.

      oleksandr-boboshko
      Oleksandr Boboshko

      Partner, Tax & Legal, Tax Advisory

      KPMG in Ukraine

      Request for proposal

      Obligation to submit SAF-T UA

      • From 27 August 2021, large taxpayers are required to provide copies of documents in electronic form at the request of the tax authority during an audit, no later than two business days following the day the request was received (para. 85.2 of the Tax Code of Ukraine).
      • From 1 January 2025, large taxpayers must submit SAF-T UA as part of their standard tax reporting (Draft Law No. 6255 dated 2 November 2021).
      • From 1 January 2027, SAF-T UA submission applies to all VAT payers (Draft Law No. 6255 dated 2 November 2021).

      Although Draft Law No. 6255 has not yet come into effect, official comments from the State Tax Service (STS) have determined that it has the right to request the SAF-T UA file from a large taxpayer during a documentary audit (whether scheduled, unscheduled, on-site, or off-site). For instance, if the audit covers the 1 January 2022–31 March 2025 period, the Ukrainian tax authorities expect to receive files for each year of said period (i.e. 2022– 2025).

      Consequently, a company may receive a request from the STS within the scope of a tax inspection even in the absence of a formal obligation to submit the SAF-T UA file as a separate report.

      It is therefore advisable for companies to prepare in advance and initiate the procedures for implementing and preparing SAF-T UA documentation.

      Implementation of SAF-T UA in Ukraine

      Implementation of SAF-T UA in Ukraine

      Download PDF

      Main Information provided in SAF-T UA

      • Accounting policies and description of accounting approaches
      • Detailed description of business transactions, including transaction coding and characteristics
      • Accounting and tax information, including transactions by date, number, source document name, and amount
      • Source documents, accounting certificates, etc

      SAF-T UA Structure

      In November 2024, the STS published an updated SAF-T UA 2.0, simplifying the XML structure, reducing the number of mandatory fields, and clarifying the data type requirements in accordance with the Ukrainian National Accounting Standards (UNAS).

      I. Header

      II. MasterFiles

      III. SourceDocuments

      IV. GeneralLedgerEntries

      Structures

      SAF-T UA: Key challenges and issues

      • Extensive detailed list of information to be provided as part of and together with SAF-T UA (compared to simplified SAF-T file versions in other European countries).
      • National specifics of the international standard:
        • Requirement to back accounting data with source documents.
        • Requirement to provide copies of administrative documents concerning approval of accounting policies and other detailed information along with SAF-T UA.
      • Tight deadlines for providing information (para. 85.2, the Tax Code of Ukraine states that large taxpayers must provide SAF-T UA no later than two business days following the day the request is received during an STS audit).
      • Search and selection of adaptive and functional software (technical solutions) for preparing SAF-T UA documentation.
      • Corporate restrictions on approaches to cooperation with local software (technical) providers.
      • Significant additional compliance burden for companies.
      • Need to search for and hire specialised technical personnel (both IT specialists and methodological consultants).

      Main Preparatory Efforts

      Software for SAF-T UA submission

      Creation of SAF-T UA file for the STS audit period

      Checking SAF-T UA generated files

      Implementing SAF-T UA in Ukraine

      How can KPMG help?

      • Methodological accounting and tax support and consulting regarding SAF-T UA file preparation
        • We provide methodological support to your company throughout every stage of SAF-T UA file preparation: from analysis of file structure and its completion, to collection and processing of company data and importing data from the company accounting registers for SAF-T UA preparation.
        • We provide consultations concerning company enquiries about tax and accounting matters during the SAF-T UA formation process.
      • Diagnostics of data the company plans to convert into the SAF-T UA file
        • We analyse the data prepared by the company for conversion into the SAF-T UA file in order to ascertain compliance with the applicable laws and tax authority clarifications.
      • Preparation of terms of reference for cooperation between the company accounting department and its IT provider
        • We assist companies in preparing terms of reference for their relevant IT provider in line with legal requirements and the latest clarifications from the tax authorities.
        • We help to establish communication between companies’ accounting departments and their relevant IT providers.
      • Diagnostics of accounting policy and recommendations for improvement
        • We analyse companies’ accounting policies and their alignment with company accounting and business processes.
        • We provide recommendations for improving accounting policies and/or update them to properly formalise accounting procedures, taking into account tax aspects and the company business processes.
      • Tax diagnostics to identify tax risks and plan measures to mitigate the risks
        • We identify tax risks and assess their materiality (i.e. amount at stake).
        • We provide recommendations to mitigate adverse consequences from identified tax risks.