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Deloitte Academy Seminar – SAF-T© 2017 Deloitte Belgium 1
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Headline Verdana BoldDeloitte Academy SeminarFrom e-Audit files upon demand to real-time reporting. Are you ready for SAF-T?Deloitte Belastingconsulenten/Conseils Fiscaux
Before we start
Please turn off your mobile phone and laptop
Deloitte Academy Seminar – SAF-T© 2017 Deloitte Belgium 4
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
Demo
Pieter 14:15 p.m. – 14:45 p.m.
(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.
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Introduction
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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
Setting the scene
Introduction
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Countries worldwide are adopting new ways of monitoring, many of these are Digital:
Digital Tax is growing fast (some examples)
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
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Different ways of Electronic Audits
Digital Tax is growing fast
Electronic audit files
Standardized Electronic audit files
Standardized Electronic
Transactions and Ledgers
Next: Blockchain ?
• 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.
Structured Format
OECD SAF-T Elements
Ad hoc Format
Structured Format
OECD SAF-T Elements
Detailed line level
Data Frequency and Format
Distributed/Shared Data
Immutable Records and audit trail.
Upon Request Periodic and (Near) Real-TimeUpon Request
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From eAudit to Real-Time Reporting
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Example: Belgium
eAudit upon demand
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
Data Requested Lead Time Typical Activities
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Example: France
SAF-T upon demand
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
Data Requested Lead Time Typical Activities
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Example: Poland
SAF-T Periodical
JPK_VAT - VAT sales & purchase register
Assistance in the preparation and filing of the reporting
Embedded in compliance process
Challenge : link with compliance process (to reconcile) + shorter lead-time
Monthly
Data Requested Lead Time Typical Activities
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Example: Brazil
Real-time reporting
Sales invoices Real-time
Data Requested Lead Time Typical Activities
Set up of the process
Embedded in the sales and supply chain process
Involvement in IT infrastructures
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Brazil: Invoice Flow
Real-time reporting
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2
3
4
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SAF-T: Introduction
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Europe: Standard Audit File for Tax (SAF-T)
SAF-T: Introduction
Periodically per legal entity 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
Across taxes, including info relating to
• VAT
• CIT
• Transfer pricing
Masterdata
Trans-action
Balances
SAF-T has been designed to capture data from a number of areas found in a typical business accounting system
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The changing face of tax complianceThe move towards Electronic Audits
Need toupdate
IT systems
Production of compliant
standard data
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 checkingof information
• Direct audits of ERP systems/ accounting software
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 checksperformed
• Incontestable proof of filing
• General lack of consistencyin testing/filing of data
• Slight country variations in format and requirements
From taxpayers’ information systems to authorities’ audit software
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SAF-T: upon request
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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 120.000,00 EUR- Small taxpayers with few transactions (+-500) so that manual
check is easier than submission of an electronic file.
SAF-T: upon request
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Country Legal ent. Non-est. VAT reg. Comments
Netherlands
Norway
All companies currently liable to maintain book-keeping information electronically.
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
SAF-T: upon request
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SAF-T: periodical
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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
SAF-T periodical
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Real-time reporting
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Country Requirement Legal ent. Non-est. VAT reg. Comments
FranceElectronic 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.
No other details yet.
Poland
Daily reporting of JPK_WB (Bank account statement) (From 1 Sept 2017)
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
SpainElectronic 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 31st 2017)
Real-time reporting
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Real-time reporting requirements
Spain – Suministro Immediato de Informacion
• 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
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Compliance impacts
Spain – Suministro Immediato de Informacion
• 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
Web portal
Tax Authority database
Consolidate and
validate data
Audit process
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Key items
Spain – Suministro Immediato de Informacion
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
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”
Dates of implementation
• Entry intro force by 1 July 2017.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- (62.000 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
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 16th dayof the following month from the accrual date
• Received invoices: Four days from its accounting. Always, before the 16th day of the following month from the accrual date
• Imports: Four days from the date in which the accounting document (in which the VAT quotais indicated) was registered. Always, before the 16th 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
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Challenges
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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
Challenges
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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
Challenges
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Break
© 2016 Deloitte Belgium 32Deloitte Academy Seminar – SAF-T
eAudit: different ways to get prepared
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Country-by-country or a strategy
eAudit: upon demand or periodical
PolandBelgium
Spain
Portugal
Spain
Poland
Portugal
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Country-by-country
eAudit Process
Country specific Data Model
Per jurisdiction, the specific data model is linked to the e-process
Country data models often captures info from General Ledger Accounts Receivable Accounts Payable Fixed Assets Inventory
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
KnowledgeSpain
PolandPortugal
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Strategic approach
Structured data model is based on the OECD SAF-T model.
Data model captures info from General Ledger Accounts Receivable Accounts Payable Fixed Assets Inventory
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
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
eAudit Process
Overall Corporate Data Model
Knowledge
Poland
Belgium
Spain
Portugal
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eAudit: Dashboard Demo
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Example for Spain
Real-time reporting process
ERP
FTP Server
1. Raw SII Data
SII convertor/generator
3. SII XML file
Spanish Tax Administration
Communication platform
4. SII XML response
SII Communication process & error
handling
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Technology Update
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Tax Analytics Implications
Exponential technologies
• 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
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Overview
Connected world
• 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
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More than crypto-currencies, Blockchains have multiple applications
Blockchain as a system
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
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
Blockchain
System
Record Keeping
Create an immutable record without reliance on a trusted third party
Improve efficiency of record keeping via automation
Transfer of Value
Enable low-cost, near real-time value transfer without an intermediary
Expand to transfer of other assets beyond “money”
Smart Contracts
Program protocols to execute transactions when a set of pre-determined conditions are met
Each application serves as the foundation for more sophisticated uses
Greater sophistication
Examples
• Digital certificate of ownership for physical assets
• Transaction validation of digital assets
• Financial accounts
• Digital cheques / IOUs
• Automatic financial instruments
• Parametric insurance contracts
• Automated market making
• Domestic and international remittance
• Internal payments settlement
• Clearing and settlement of securities
• Exchange of low liquidity assets
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Example – High Level overview of a system using electronic messaging with shipment approval and confirmation
Example for Physical Supply of Goods
Vat automation in the Digital Supply Chain
Approval
e-Invoice
Paper Invoice
Approval Code
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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.
Possible Blockchain applications?
VAT and Blockchain
120
20
Blockchain
Bank transfer
MessageVAT N°
Taxable amount and VAT
Description good/service
Etc.
20
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Faster:
From ad-hoc to monthly and real-time.
Immediate response required!
Better:
Eliminate error prone process and manual interventions
Tax sensitive process should be touchless
Controlled:
Measure and Monitor change and deviations
Full transparency
No Mistakes allowed.
Invoice and Document Management.
Integration management.
Tax Reporting and Automation
Data and Process Analytics.
Business Process and Activity monitoring.
Process orchestration, full end-to-end integration
How to prepare
Some Design thinking to your ERP
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
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Final Conclusions
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Key Messages
Final Conclusions
Technology is the tool, Data is the FuelThe 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 AlignmentIt assumes alignment, formalization and standardization in business processes far beyond your tax function.
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.
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Next Steps
Final Conclusions
Get a view on your process and data qualityWhere are the gaps?
2Get connected.take the lead and ensure external regulatory requirements are in line and with the internal organization. This includes the business and IT.
1
Deloitte Academy Seminar – SAF-T© 2017 Deloitte Belgium 48
Liesbet Nevelsteen
Partner, Indirect Tax
Work : +32 2 600 66 53
Mobile : +32 496 57 48 79
Frederik Drappier
Senior Manager, Indirect Tax
Work: +32 2 749 54 77
Mobile: + 32 496 26 16 64
Pieter Van Dyck
Senior Manager, Tax Management Consulting
Work: +32 2 800 25 65
Mobile: +32 497 53 29 73
Contact Information
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© 2017 Deloitte Belgium
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Annex
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eAudit Process
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• 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
Analysis of the technical Set up & Processes
Aanalysis
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Extract the tax relevant data from the different source systems identified during the analysis
Data Extraction
• 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.
SAP DART
TJC
SNI
SAP OSS Notes
Data Warehouse
…
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Extracted data should be validated prior to the assembly of the eAudit file
Data Validation
Records
Master Data
Company Code
Fiscal Year
Transactions
Lines
Vendors/Customers
Tax Codes
Data Mining Tools:
– Caseware IDEA
– ACL Analytics
Customized Data Warehouse Queries
…
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The extracted data should reconcile official filings
Data Reconciliation
Automated
Not Automated:
Sample testingCriteria:- Fiscal Year- Business Events- Size- Etc.
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Assemble the extracted data into an eAudit file according to the local requirements
Assembly
• 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
SAP OSS Notes
Data warehouse queries
Data Mining Tools:
– Caseware IDEA
– ACL Analytics
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• 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
Real-time vs upon demand/periodical
Process