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Poland’s Next Step After SAF-T – Centralized E-Invoice

Gabriel Pezzato
March 18, 2020

The expansion of Poland’s new SAF-T report (JPK) barely took effect before Poland is steaming ahead with a more far reaching plan.  It aims to introduce a centralized e-invoice system via an exchange platform in 2022.

In an interview published on the Polish Ministry of Finance webpage, the Minister of Finance says that implementing mandatory e-invoicing in public procurement is a pilot project that may be expanded to B2B transactions on a voluntary basis in 2022.

The Minister explains the government is considering a range of different approaches to introducing e-invoices in the country, including an exchange platform through which suppliers and buyers can exchange invoices electronically. He mentions the Italian clearance system as an example and that, in clearance systems, the tax authority is part of the issuance process in which invoices are pre-authorized (cleared) in an automated way.

Poland moves to a clearance regime

Poland already allows the use of e-invoices, as a post audit regime without involvement from the tax authority. Under the current framework, the issuer must comply with some requirements, such as ensuring the integrity of the content, the authenticity of the origin, legibility of the invoice and the buyer must agree to receive invoices electronically. Although the exact details aren’t yet known, the new e-invoice system is expected to involve the tax administration during the issuance process, i.e. Poland will move from post audit to a clearance regime.   

The Polish government aren’t expecting to receive additional data from taxpayers as a result of introducing an e-invoice system but they do expect to receive it quicker. The tax authority already holds all necessary taxpayer data collected through the JPK reports. Nevertheless, an e-invoicing system would communicate data in real-time to the tax authority enhancing the efficiency of the tax system.

The benefits to Poland’s economy

The Minister cites the simplification for entrepreneurs and enhanced security among the benefits of introducing an e-invoice system in Poland. Buyers will also benefit as they’ll be able to download invoices issued to them from a centralized storage.  If introduced successfully it’s likely that the JPK returns will be discontinued, further reducing the administrative burden imposed on taxpayers.

In the interview, the Minister acknowledges the success Italy has had in mandating clearance e-invoicing. Italy has led the way in implementing continuous transaction controls in Europe, with its mandate having sought a derogation of the VAT Directive from the European Commission. We suspect the Minister’s reference to the Italian model may indicate the Polish government is open to following the same bureaucratic pathway.

This announcement from the Polish government is an indication that taxpayers must, more than ever, be alert to the rapidly changing environment for tax compliance in Poland. As more countries see the benefits from introducing continuous transaction controls in closing VAT gaps, Poland may be the next country to follow Italy’s lead, but it certainly won’t be the last. 

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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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