September 17, 2020
Poland implements new VAT reporting requirements
On 1 October 2020, Poland’s new value-added tax (VAT) reporting requirements will take effect. The traditional VAT return will be replaced by the JPK_V7M file, the new SAF-T file that combines information from the VAT return and the SAF-T file now in use, requiring new information to be included in the revised template.
The planned entry into force of the new law was postponed twice as a stimulus measure to alleviate the effect of COVID-19. Currently, there is no discussion on any further postponement and all Polish taxpayers will be required to file their VAT reports for October 2020 by 25 November 2020, using the new file.
This affects all VAT taxable persons in Poland, i.e., not only entities established in Poland but also nonresidents with Polish VAT registration numbers.
The implementation of the new SAF-T file presents a number of challenges for taxpayers. First, IT readiness must be ensured, which means that either the tools currently used for SAF-T/ERP systems must be updated/upgraded or a new tool implemented. Second, data completeness and accuracy should be considered, as all the required data must be identified and captured, which can pose difficulties both in terms of the content and the technical requirements.
The technical accuracy of a file is critical, otherwise the file will be rejected at the e-filing gate. Similarly, as the information supplied in the files is tested by tax authorities, the accuracy of the content cannot be overlooked.
While the new JPK_V7M file includes summary data, it also features a section on individual transactions. The scope of the required information is broader in comparison to what is currently reported. The new information required at the transaction level includes in particular:
Some information set out above will be required with respect to purchase transactions.
Improper implementation of the JPK_V7M file may carry substantial penalties.
Tax authorities can charge a penalty of PLN500 (€110) for each mistake in the file. Furthermore, failure to submit the new SAF-T file at all or an SAF-T that is found to be an unreliable declaration or records may result in the penal tax consequences for the individuals in charge.
Preparing for implementation
Taxpayers should assess the following questions to determine whether the business is ready for the new requirements. They include:
For additional information with respect to this Alert, please contact the following:
EY Doradztwo Podatkowe Krupa sp. k., Warsaw