VAT records requirements for sellers, deemed supplier marketplaces and Intermediaries for on-demand VAT audit requests –SAF OSS XML schema
The One Stop-Shop (OSS) and Import One Stop-Shop (IOSS) VAT returns were introduced in the EU on 1 July 2021 as part of the e-commerce package. They are single pan-EU VAT returns for distance selling (OSS) and imports sales not exceeding €150 (IOSS).
Data recordkeeping and reporting obligations
Sellers, facilitating marketplaces or Intermediaries using these returns have detailed electronic data OSS and IOSS recordkeeping and reporting requirements in addition to the regular returns filing process. This is detailed in Council Regulation 282/2011 (Article 63c). Audits or supporting data requests can come from any country where the OSS or IOSS party is selling to, but channelled via the tax authorities were they have registered (member state of identification.
SAF-OSS to harmonise VAT data requests
A new standard format, OSS Standard Audit file for these data requests has been set by the EU. When requested for VAT transaction support data based on their IOSS or OSS returns, the seller or Intermediary can use this format to report. This is similar to the OECD SAF-T format, which helps standardise tax information exchanges and is growing in adoption across Europe.
If you need to complete SAF OSS or other SAF-T submissions, VAT Calc’s VAT Filer can accurately populate any country submission with verified VAT or GST data from our VAT Calculator or VAT Auditor services
It includes the following elements:
- Top Element: Header; Masterfiles; Transactions; and Stock Movements
- Address: Post code; Address is not known, this element must be filled in with “Unknown”; and optional address; Country ISO
- Billing Type: address and country
- Billing Indicators: source billing
- Currency: ISO code; amount; FX rate
- Customer location evidence – location or billing
- Customer type: unique customer ID; tax ID; names; address; ship to address
- Customer country: ISO code
- Provider location: tax ID; name; country ISO
- Document type: delivery note; transport; return note; consignment note
- Document amounts: tax payable; amount; gross total; currency; payment type
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Standard Audit File for Tax SAF-T countries
| Country (click for details) | Date | Scope | |
| 13 | Bulgaria | 2026 | Phased introduction over two years |
| 12 | Ukraine | Jan 2025 | Phased 2025 to 2027 implementation |
| 11 | Denmark | Jan 2024 | Phased implementation from 2024 |
| 10 | Romania | Jan 2022 | Mandatory monthly filings initially large taxpayers (due Jan 2023) |
| 9 | EU OSS & IOSS | Jul 2021 | On-demand for sellers, marketplaces or Intermediaries |
| 8 | Norway | 2020 | Replaced VAT return 2022 |
| 7 | Angola | 2019 | On-demand |
| 6 | Lithuania | 2019 | On-demand; residents and non-residents above €30,000 sales threshold |
| 5 | Poland | 2016 | Mandatory, monthly replaced VAT return Oct 2020 |
| 4 | France | 2014 | On-demand |
| 3 | Luxembourg | 2011 | On-demand |
| 2 | Austria | 2009 | On-demand |
| 1 | Portugal | 2009 | Monthly for residents and non-residents (Jun 2022) |
