Preparing for Poland’s New JPK_VAT Structure

Jeff Gambold
May 5, 2020

We recently reported the Polish government’s decision to delay introduction of the new JPK_VAT  with a declaration structure until 1 July 2020. This move is part of the country’s Tarcza antykryzysowa (“Anti-Crisis Shield”) initiative to support business during the coronavirus pandemic and gives welcome extra preparation time especially as the Ministry of Finance only recently published the finalised schema and explanatory guidance.

Given the extension, now is a good time to recap some of the main features and the surrounding compliance regime.

Scope

New JPK_VAT is a periodic filing combining the current JPK_VAT single audit file and VAT-7M (monthly) and VAT-7K (quarterly) VAT returns within one document.  It has the same deadline as the current separate submissions of 25th of the month following period end. Taxpayers filing quarterly will also need to submit a monthly registration part. JPK_VAT will not include any other periodic VAT filings (e.g. VIES declarations, which still need to be submitted separately using form VAT-UE).  Businesses should ensure their compliance processes are organised to reflect the change.

Additional data

The new JPK_VAT requires additional data to that currently collected in the separate declarations. For example, sales records will need to include indicator codes specifying certain types of goods and services, transaction types, and proof of sales. Purchase records will need to include tags specifying proof of purchase, along with tags for transactions subject to specific procedures, e.g. goods imports and split payment. For example, the marking ‘MPP’ should be applied to any invoice documenting a split payment transaction (any categorised in Article 15 of the Polish VAT Act) with a VAT-inclusive value of over PLN 15,000; this invoice is recorded in the MPP field within JPK_VAT. Such marking and recording helps make audits more efficient for the tax authority, but businesses should review their invoice content requirements and align AR, invoicing and reporting personnel to minimise errors.

 Penalties

It was originally intended that a financial penalty would apply to any mistake found within a submitted JPK_VAT file. The Ministry of Finance has recently confirmed that penalties will instead be applied on a discretionary basis, subject to appeal. This suggests minor discrepancies won’t necessarily incur a fine if they don’t result in material risk to VAT payments by the taxpayer or by its immediate suppliers or customers.

Corrections

The most recent guidance states that corrections to declarations submitted in the previous and now replaced JPK_VAT and VAT-7 formats should also be reported in the same way. For the new JPK_VAT structure, only the part requiring correction must be completed. The correcting document must include all transactional data for the period being adjusted, not just the data requiring correction.

From which VAT declaration periods does new JPK_VAT start?

The most recent guidance states the new report is required “by all registered as active taxpayers for the periods from 1 July 2020.”  It later reads “for periods from 1 July 2020, it will not be possible to submit VAT-7M and VAT-7K declarations and records other than in the form of the new JPK_VAT.”  These two statements indicate that the first mandatory new JPK_VAT submission will be the JPK_VAT7M for the month of July 2020, due no later than 25 August 2020.

Take Action

To find out more about what we believe the future holds, download Trends: Continuous Global VAT Compliance and follow us on LinkedIn and Twitter to keep up-to-date with regulatory news and other updates.

Sign up for Email Updates

Stay up to date with the latest tax and compliance updates that may impact your business.

Author

Jeff Gambold

Jeff Gambold is a Senior Regulatory Specialist at Sovos, with responsibility for ensuring that the SVR product is kept updated and compliant with the latest VAT legislative changes. Prior to joining Sovos, Jeff worked in various VAT advisory and management roles within HMRC, UK Top 15 accounting practices and commercial business.
Share This Post

LATAM VAT & Fiscal Reporting
May 20, 2020
Sovos Acquires Taxweb, Extends Tax Determination Capabilities in World’s Most Challenging Compliance Landscape

Earlier this month Sovos announced its second acquisition of 2020, completing our solution for Brazil with an unparalleled offering that solves tax compliance in the place where it is most challenging to do so.  Too many companies doing business in Brazil have been burdened by managing multiple point solutions for continuous transaction controls (CTCs), tax […]

Tax Compliance Tax Information Reporting United States
June 1, 2020
The Advantage of a Cloud-First Company

With the acquisition of Eagle Technology Management (ETM) and Booke Seminars, Sovos has united the very best in statutory reporting solutions, technology and expertise. Below is an overview of our strategy following these acquisitions: Sovos’s SaaS and Security Strategy  Sovos at its core is a Software as a Service (SaaS) and cloud-first company. This means […]

ShipCompliant United States
May 28, 2020
Ask Alex: Your Bev Alc Compliance Questions Answered (May 2020)

Do you have questions about the rules, regulations, and compliance requirements of the beverage alcohol industry? This series, Ask Alex, is a perfect opportunity to get those pressing questions answered straight from one of the industry’s regulation and market experts, Alex Koral, Senior Regulation Counsel, Sovos ShipCompliant.  To take advantage of this opportunity and get […]

E-Invoicing Compliance EMEA
May 28, 2020
Turkey’s Transition Conditions for E-ledger

On October 19, 2019, the Turkish Revenue Administration (TRA) published a communique making the e-ledger application mandatory for e-invoice users, companies subject to an independent audit, and companies identified by the Presidency to have poor tax compliance.  The e-ledger application enables businesses to create the legally mandated general journals and ledgers and submit e-ledger summary […]

ShipCompliant United States
May 27, 2020
How Technology Partnerships Improve DtC Compliance

To be an expert, one has a specialty. Ours is beverage alcohol compliance. Since compliance sits at the heart of operations, being connected at every step helps our customers focus on their business instead spending countless hours on manual processes. Compliance is challenging, but we make it easier with a large and robust network of […]

EMEA IPT Tax Compliance
May 26, 2020
Why IPT Reporting is so Complex for Insurers

Accurately calculating insurance premium tax (IPT) for reporting can be complex.  And the ramifications of getting it wrong can be far reaching from impacting profit margins to unwelcome audits, fines and damage to your company’s reputation in the market and with customers. Calculation methods When I speak to customers about how they calculate insurance premium […]