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Poland: JPK V7M/K Schema Changes from 1 January 2022

Kelsey O'Gorman
October 11, 2021

Poland implemented its version of a mandatory SAF-T file (the JPK_V7M/K reports) back in October 2020. Since then, businesses must submit detailed information on invoices, along with summary reporting details typically seen in a VAT return.

The Ministry of Finance recently adopted amendments to the mandatory JPK_V7M/K reports, effective 1 July 2021. However, in order to gives businesses ample time to implement these changes, the schema changes do not become effective until 1 January 2022.

The tax authorities have prepared draft versions of the new schema changes to allow for businesses to make any technical changes needed well in advance of the implementation date.

Highlights

  • Split payment marker removed
  • The July amendment provided that businesses no longer need to use the special invoice marker “MPP” to indicate when split payment had been used. As such, the new draft schema posted by the tax authorities does not include “MPP”.

  • Distance sales marker removed and replaced
  • When JPK_V7M/K was first implemented, distance sales transactions, which at the time of commencement of their shipment or transport, are within the territory of the country, were to be marked with “SW” while the marker “EE” was to be used for the certain transactions relating to telecommunications, broadcasting and electronic services. For a transitional period from 1 July 2021 through 31 December 2021, transactions that were typically marked with the “SW” marker should now be marked with the “EE” marker, effectively removing “SW” as an option.

    From 1 January 2022, the marker “WSTO_EE” should be used for intra-community distance sales of goods as well as the provision of telecommunication, broadcasting, and electronic services to non-registered taxpayers in EU Member States other than Poland. This aligns with the introduction of EU E-commerce package from 1 July 2021, so it’s not surprising that Poland has combined “SW” and “EE” markers into one.

Other changes

  • Introduction of “IED” marker which is to be used for supplies of goods to the country by taxpayers facilitating such supplies by electronic interfaces or for supplies of this type of outside of special procedures (i.e., OSS or IOSS scheme) in Poland or other Member States.
  • GTU designations will not be applicable to internal documents (marked as “WEW”) and cash register reports (“RO”).
  • The marker “TP” is no longer required in the case of the supply of goods and the provision of services, when the relationship between the buyer and the supplier of goods or service provider results only from the relationship with the State Treasury or local government units or their associations.

In addition to the changes described above, Poland has set out numerous other changes that can be found here.

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Author

Kelsey O'Gorman

Kelsey O’Gorman is a Regulatory Counsel at Sovos. Within Sovos’ Regulatory Analysis function, Kelsey focuses on global sales tax and VAT issues, supporting both the tax determination and reporting engines. Kelsey received her B.A. in Psychology from University at Buffalo and her J.D. from Roger Williams University School of Law. She is a member of the Massachusetts Bar.
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