Article

Requirement for a Standardized Audit File for Tax (FAIA) for Luxembourg VAT purposes

Is your company in the scope? Are your systems ready? Try our dedicated TEST!

What is the FAIA - Fichier Audit Informatisé AED?

As was already the case in a few countries in Europe, Luxembourg VAT authorities have now decided to apply the OECD recommended standard audit file for Tax audits and, in particular, for VAT audits (SAF-T). The SAF-T (referred to as FAIA - Fichier Audit Informatisé AED in Luxembourg) is a standard file designed to export accounting and static data upon a request by the VAT authorities in the context of a VAT audit.

Following a pilot phase, the authorities are now progressively intensifying their request for FAIA files, starting with the audit of 2010 /2011 VAT returns (audited in 2015/2016). It is essential for businesses across all sectors to ascertain whether they are in the scope of the obligation to provide a FAIA file, review their current accounting and IT systems, and to perform any necessary adjustments required to ensure compliance with the new standards.

Is your company in the scope of this FAIA requirement?

Based on the Luxembourg VAT law, any entity qualifying as a taxable person for VAT purposes could be required to provide a FAIA file upon request from the VAT authorities. The VAT authorities have, however, decided to split the implementation of this FAIA file requirement in two phases:

  • Phase I: The FAIA requirement applies to all taxable persons other than small businesses, taxable persons benefiting from a simplified VAT regime, and taxable persons which are exempt from Standard Chart of Accounts (PCN) obligation.
  • Phase II: The FAIA requirement will be extended to all taxable persons.

It is, therefore, of the utmost importance for you to determine whether your company falls in Phase I or Phase II of this implementation. Our test is designed to assist you in making such a determination.

What FAIA must your company be ready to provide?

Depending upon the integration of your accounting system, the type of FAIA file you will be required to produce may be either the "FAIA full version""FAIA reduced A" or "FAIA reduced B".

Our test will assist you in determining which of these FAIA files is required to be produced by your company for the Luxembourg VAT authorities.

Assess your FAIA readiness

If your company is in the scope of the FAIA obligation, an additional set of questions will provide you with an answer to a third question: Is(are) my accounting system(s) ready to comply with my FAIA obligation, or to what extent must my system(s) be adapted?

Regarding this FAIA readiness assessment, we will be glad to meet with you to disclose the outcome of the test in a free of charge, face to face meeting with one of our Luxembourg FAIA experts.

Our proposed services

We have developed a full service offering in relation to the new FAIA regime, ensuring that we would be able to provide you with whatever assistance you may require. Overall, our goal is to help you to feel comfortable that you could provide the necessary FAIA file upon request by the VAT authorities. In line with this goal we would be happy to:

  • assist you in understanding the scope of the FAIA obligations and requirements;
  • test the compliance of the format of your FAIA file prior to its submission to the VAT authorities;
  • assist you in the production of your FAIA file; and
  • review the content of your FAIA file from a Luxembourg VAT perspective.
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Our FAIA experts

Christian Deglas
Partner
Indirect Tax VAT
+352 451 452 611
cdeglas@deloitte.lu

Cedric Tussiot 
Director
Indirect Tax VAT
+352 451 452 604
ctussiot@deloitte.lu

Antoine Farioli 
Director
Indirect Tax VAT
+352 451 452 522
afarioli@deloitte.lu

Edwige Clément
Senior Manager
Indirect Tax VAT
+352 451 452 560
eclement@deloitte.lu

Eric Reolon
Senior Manager
Indirect Tax VAT
+352 451 453 677
ereolon@deloitte.lu

Thijl Duval
Senior Manager
Tax IT Innovation
+352 451 453 032
tduval@deloitte.lu

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