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.


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.


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.


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.


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

North America ShipCompliant
May 25, 2023
Out-of-State Breweries Gain Self Distribution, DtC Rights in Oregon

Under a settlement agreement, breweries located outside of Oregon now have more options for selling into the Beaver State, including direct-to-consumer (DtC) shipping and self-distribution to retailers. The settlement arose out of a lawsuit filed by a group of Washington breweries last year challenging Oregon laws that limited beer self-distribution to in-state breweries and DtC […]

EMEA VAT & Fiscal Reporting
May 24, 2023
VAT and Art: What you need to know

Significant inflation increases have impacted most of the world’s economies, with the UK still above 10% in 2023. This increase means a reduction in the purchasing power of consumers. Together with increases in the cost of raw materials, this has created uncertainty regarding growth of entire industrial departments and reduced profit margins for companies. The […]

North America ShipCompliant
May 23, 2023
Top 5 Myths Surrounding Retailer Direct-to-Consumer Wine Shipping

By Tom Wark, Executive Director, National Association of Wine Retailers Politics breed myths. This has always been the case as politics is, at its most fundamental, a form of storytelling. So it should be no surprise that myths have arisen as various elements of the wine industry have fought against consumers and specialty wine retailer seeking […]

May 23, 2023
IPT: Location of Risk and Territoriality

Much of the discussion on the Location of Risk triggering a country’s entitlement to levy insurance premium tax (IPT) and parafiscal charges focuses on the rules for different types of insurance. European Union (EU) Directive 2009/138/EC (Solvency II) set out these rules. However, a related topic of growing importance in this area concerns territoriality, i.e. […]

Asia Pacific E-Invoicing Compliance
May 23, 2023
Japan: New e-Invoice Retention Requirements

Japan’s new e-invoice retention requirements are part of the country’s latest Electronic Record Retention Law (ERRL) reform. Along with measures such as the Qualified Invoice System (QIS) and the possibility to issue and send invoices electronically via PEPPOL, Japan is implementing different indirect tax control measures, seeking to reduce tax evasion and promote digital transformation. […]