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Poland is Moving Fast: CTC E-Invoicing Draft Law Available for Public Consultation

Gabriel Pezzato
February 8, 2021

The Polish Ministry of Finance has now published the draft act introducing e-invoicing via the national platform (Krajowy System e-Faktur – KSeF, or National System of e-Invoices) in a Continuous Transaction Control (CTC) system. The draft is available for public consultation during a two-week period, after which the law is planned to come into force already by 1 October this year.

However, by this date, issuing and receiving invoices via the national platform will be voluntary; both paper invoices and other e-invoices will continue to be permitted. Taxpayers opting to use the KSeF system will be rewarded with quicker VAT refunds. Security, convenience, and efficiency are other factors that are mentioned as benefits for those using the system. The plan is to then make use of the KSeF system mandatory in a second step by 2023.

A couple of noteworthy features of the new invoicing system are the following.

  • To be able to issue invoices through the CTC system, the recipient’s acceptance is required. An acceptance under previous rules to just receive invoices in electronic form is not sufficient.
  • Issuance and receipt of the invoice is deemed to take place in the platform.
  • Outsourcing of issuance or receipt of invoices is possible and regulated.
  • Use of digital signatures is required; a qualified electronic signature is explicitly mentioned.
  • The KSeF system includes archiving functionality; invoices issued through the system will by default be archived for ten years from the end of the year they were issued.

The Polish proposal draws quite heavily on the Italian SDI system. Poland is establishing a transitory period before making e-invoicing through a clearance platform mandatory, just as Italy did before introducing its full-fledged CTC e-invoicing mandate. The proposal to offer an e-archiving solution off the shelf mirrors a similar feature of the Italian SDI platform; the Italian platform, however, received criticism around privacy concerns and had to be adjusted on the fly. Another feature that resembles the Italian model is the relationship between the reporting of invoice data with data gathered by the clearance platform. While Italy had discontinued the Spesometro (report of domestic invoices) – and will also discontinue the Esterometro (report of cross-border transactions), Poland will exempt taxpayers from the obligation to submit the JPK_FA (report of invoices).

It is noted that the draft law allows for more detailed rules to be added by ministerial decree, so it may still be some time before all is set. It does indeed look like the Polish will stick to their intention to have their CTC up and running before France.

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Gabriel Pezzato

Gabriel Pezzato is a Senior Regulatory Counsel at Sovos. Based in Stockholm and originally from Brazil, Gabriel’s background is in tax, corporate and administrative law. Gabriel earned a Law degree and a specialization degree in Tax Law in his home country and has a master’s degree in International and European Tax Law from Uppsala University (Sweden).
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