New digital VAT reporting from 2022

Introduced from 2022

As a part of the Norwegian Tax Authority’s project for modernization VAT, it is announced that a new VAT return format will be piloting this summer and expected in force from the first VAT period in 2022. For many companies, this will be perceived as a relatively short timeframe to prepare for the upcoming changes.

The new VAT return will apply to companies with standard (bimonthly), shorter, and longer (annual) VAT reporting periods. Filing and payment deadlines are expected to remain the same as today.

XML format based on SAF-T codes

The new VAT return will be in XML format and are based on the SAF-T code list. This means it will be more itemized than today's aggregated VAT return (30 vs. 19 lines). The Tax Authority has published technical documentation describing the XML format and the SAF-T code list. Disclosure of additional data related to losses on outstanding claims, adjustment or reversal of input VAT, and withdrawals may also be required.

Mapping of the company's internal VAT codes to the corresponding SAF-T code list is a mandatory part of the SAF-T standard that became the mandatory format for the export of accounting information recorded from 1 January 2020. Resources already invested in SAF-T mapping will serve as a stepping stone in the adaption process.

The new VAT return is independent of the SAF-T file even though it is based on the SAF-T codes. However, since the SAF-T file represents the accounting data that forms the basis for the VAT reporting, it is essential to ensure coherence between the SAF-T file and the VAT return.

Reporting from accounting system (ERP)

The aim is that the new VAT return generally will be submitted from the accounting system (ERP). Considering more than half of the VAT returns are currently manually filed in the Altinn portal, many companies need to adapt to this change. On the one hand, filing directly from the ERP system minimizes the risk of incorrect input and takes less time. On the other hand, it reduces the flexibility to make manual corrections and consolidations before submission and requires higher data quality. The Tax Authorities are however also developing a portal solution in Altinn to support manual filing.

New sales and purchase list

Norway is also considering introducing periodic electronic reporting of sales and purchase transactions for bookkeeping and public enterprises along with the VAT return. All invoiced sales and purchases at transactional level shall be reported, i.e. information about the trading partners, date, invoice number and amounts including specification of VAT amounts. Private individuals will not be identified. Cash sales should not be reported.

Such listing entails an extended duty of disclosure and will require legislative changes. A consultation draft is currently under consideration by the Ministry of Finance. Further clarifications are expected early this year.

Expecting more clarifications

Further clarifications for the new digital VAT return are expected in the beginning of this year, hereunder:

• How losses on outstanding claims, adjustment or reversal of input VAT and withdrawals should be specified 
• Reporting of manual journal entries with VAT (without VAT codes)
• Reporting for VAT groups
• Reporting solution for companies that are not using an ERP system

Join us on this journey!

Deloitte is already assisting several businesses with both analysis and reconciliation of SAF-T files with very positive feedback. Get in touch - and we are happy to assist with the analysis of SAF-T files, reconciliation with VAT return, mapping, or other SAF-T related issues.

Our aim is to offer functionality to fulfill the new XML based VAT return filing requirement. More information will come soon!