By Deanna Mollett, Partner & Director of ILM Services
In our recent “DART Vader” blog post, we reviewed what can be the ‘Wild Space” of supporting and keeping the Data Retention Tool, a.k.a. DART, updated and compliant.
To DART or not to DART is the question we’re exploring in this series. In the previous post, key considerations for integrating DART (or not) were presented, including aspects related to auditing and the assignment of roles and responsibilities. This second blog post dedicated to DART further expands on key roles in the system and offers information about tax audit scenarios and special conditions for non-U.S. systems.
Question: What is Z1, Z2, and Z3 access?
In short, Z1, Z2, and Z3 define how data is provided and accessed in a so-called “tax inspection.” Even if Corporate is based outside Germany, if tax filings are performed on a local level, part or all of this access may be applicable. Tax inspections are bi-directional, meaning that the auditor may start at the account summary level, then work down to the details. On the flip side, the inspection may start in the details and work up to the summary.
Guidelines maintained by government finance authorities–dating as far back as 2001 and updated as recently as January 20151–are foundational to DART’s evolution.
Support notes for Z1 auditor roles, such as note 2212390, serve as excellent examples of how system updates respond to guidelines and requirements. The DSAG GDPdU workgroup requests updates in response to ever-evolving requirements. In June 2015, new guidelines for minimum data from DART “data extract splitter” were published. Updating internal processes to current standards is an important consideration when determining how to integrate and support DART Z1, Z2, and Z3 access. This visual explains the data and roles involved in Z1, Z2, and Z3 access scenarios:
Key Considerations: The order of “Z1, Z2, and Z3” can be misleading, because Z1 is not where the audit starts. Z3 is the most common starting point. The important takeaway here is to be prepared with updated and compliant tools.
Z2 and Z1 access are follow-up activities to Z3 audit response. Z2 access is basically performed by internal users to obtain and provide data in the format requested by the auditor. In GoBD principles, auditors may look for evident process controls and also have the ability to “reproduce” a transaction. This is where Z1 access weighs in. Z1 access entails an auditor’s direct log-in to a special “auditor’s workplace” in the system, which is set up for this type of access. The composite role SAP_AUDITOR_TAX is available for Z1 security authorizations.
Audit cycles for German companies may not be limited to annual events. Requests for Z3 data can be received within months of a closed period, even in the same fiscal year!
Question: What enhancements for France are available in DART?
The legal requirement specified by French tax authorities (FEC), per Article L47 A-I, is to submit accounting document records for the closed fiscal year in a “de-materialized” format. SAP DART is enhanced to deliver in the required data format in order to meet these French legal requirements. These features are provided specifically to meet French guidelines:
- Mandatory French language in extracts and view (report) files
- FEC-required column and field descriptions
- Inclusion of opening balances in the DART extract
- Standard view 2FR_FI01 “DART” report designed for “de-materialized” formatting
This visual offers one example of a process flow and roles involved with FEC DART reporting:
Key Considerations: The new layer of a “business” pre-processing step with the balance carry forward adds a little more complexity. This can be managed through a DART people/process/procedure model. If DART has been executing for companies assigned country code “FR” or French territories (of other country codes) without adapting to FEC requirements as outlined in this post, it’s worth pausing for a moment to identify possible non-compliance exposure. FEC enhancements are delivered through support pack updates or support notes. The minimum DART version requirement is 2.7, and the list of notes to install for FEC enhancements follow a specific order. Recommended reading on this subject is support note 2162977.
More Key Considerations: Setting realistic timeline objectives is very important for prepping the company for audit response. It is not unheard of as part of the ramp-up to collaborate with auditors in part to validate data extract formatting. Auditors may use a tool called “IDEA,” which is short for Interactive Data Extraction and Analysis. This tool uploads files from DART or other exports to perform transactional forensics.
Finally, DART serves dozens of localized country-specific requirements. Support notes 663007 and 1463497 were recommended in our last blog post as resources for insight into positioning and utility of DART for companies based outside the United States. We hope this overview of two very different audit models served from the same tool was informative.
If you have other questions about DART and the role it might play in your organization’s compliance readiness, we invite you to contact us. Simply ILM has nearly two decades of experience in providing data archiving and DART support at both a local and global level. Call or email us today to learn more.
1, 2 “Principles for the proper management and storage of books. Records and documents in electronic form, as well as data access (GoBD)”, BMF (Federal Ministry of Finance), 14 November 2014.
