Poland’s VAT Requirements

Poland’s CTC and SAF-T framework

In an effort to modernise its tax systems and close the VAT gap, Poland’s tax authority, the Krajowa Administracja Skarbowa (KAS), continues to advance its implementation of VAT reform with changes to SAF-T and the introduction of continuous transaction controls (CTCs).

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SAF-T evolution

Poland introduced its Standard Audit File for Tax (SAF-T) system known as Jednolity Plik Kontrolny (JPK) in 2016. This incorporated seven regulated JPK structures, of which two, JPK_VAT and JPK_FA, were relevant for VAT. The requirement for monthly submissions of JPK_VAT, was extended to all taxpayers on 1 January 2018. JPK_VAT was combined with the VAT return during 2020 and the consolidated JPK_V7M/K is submitted per the frequency of the VAT Return (monthly or quarterly). The remaining six JPK structures are submitted upon request of the tax authority in event of an audit.

SAF-T quick facts

There are seven Polish JPK structures that taxpayers should be prepared for. Most are required on demand, but the JPK­_V7M/K must be submitted periodically (monthly or quarterly).

  • JPK_V7M/K declaration for records of VAT purchases and sales combined

  • JPK_FA for VAT and VAT invoices

  • JPK_WB for bank statements

  • JPK_PKPIR for revenue and expense ledger

  • JPK_EWP for revenue account

  • JPK_KR for accounting books

  • JPK_MAG for warehouses

CTC reforms

Aiming to combat fraud and improve tax collection capabilities, Poland’s first Continuous Transaction Controls (CTC) legislation, the Krajowy System e-Faktur (KSeF), was published in Poland in early 2021. Following consultation with industry representatives , the proposed CTC reform was adopted on 18 November 2021. The implementation process is ongoing, with the voluntary phase having begun in January 2022.

CTC quick facts

Participants who wish to get ahead of the mandate can now opt to use the Polish electronic invoice in structured XML format the FA-VAT, to submit supplier invoices to the KSeF (Krajowy System e-Faktur) electronically.

Other considerations for businesses include:

  • During the voluntary phase, buyer acceptance of e-invoices is necessary (otherwise supplier will still need to issue invoices in the agreed form/format, such as PDF, paper or via EDI)

  • Refund period reduced from 60 to 40 days

  • Incentive for businesses to issue invoices through the KSeF portal during voluntary phase

  • Outsourcing will be permitted though this is subject to additional rules (i.e. accountants accessing the portal on behalf of their clients)

  • All invoices will be archived and electronically stored for ten years

  • A qualified electronic signatures or seal (QES) will be required to authenticate access to the portal

Mandate rollout dates for SAF-T and CTCs

Poland SAF-T

  • 1 July 2016: SAF-T is introduced in Poland
  • 1 January 2018: Poland mandated JPK_VAT for all taxable persons
  • 1 October 2020: JPK_V7M/K replaces JPK_VAT and VAT Return
  • 1 July 2021: Amendments to the mandatory JPK_V7M/K were adopted
  • 1 January 2022: amendments to the JPK_V7M/K structure including changes to better align it with the EU e-Commerce VAT package

Poland CTC

  • 29 October 2021: legislation for a Continuous Transaction Control (CTC) e-invoicing system was adopted; draft specifications were released and test system made available
  • 1 January 2022: Voluntary phase begins for the CTC system. There is no obligation to use the e-invoicing system in B2B transactions though there are several benefits if businesses chose to do so, including quicker tax refunds and exemptions from submitting the report of invoices, JPK-FA
  • 30 March 2022: Poland is granted derogatory decision by the European Commission both from the Article 218 and Article 232 of Directive 2006/112/EC. The decision will apply from 1 April 2023 until 31 March 2026, after receiving the last approval from the EU Council
  • 7 April 2022: Test version of the KSeF Taxpayer Application made available
  • 1 April 2023: The CTC system is expected to become mandatory

  • 17 May 2022: Production version of the KSeF Taxpayer Application made available

  • 10 June 2022: The Council of the European Union published the Council Implementing Decision authorizing the Republic of Poland to apply a special measure derogating from Articles 218 and 232 of Directive 2006/112/EC. The decision will apply from 1 January 2024 until 31 December 2026, after being published in the Official Journal of the European Union

  • 1 July 2024: The CTC system is expected to become mandatory

Penalties

The new SAF-T structure, like the JPK_VAT and VAT returns, must be submitted monthly, or quarterly. Failure to submit accurately and on time may result in penalties. The Polish tax authority will react quickly to inconsistencies detected in SAF-T files and use data analysis algorithms to identify fraudulent transactions.

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Poland's SAF-T Requirements

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Poland CTC Requirements

Understand more about Poland’s continuous transaction controls including when businesses need to comply and how Sovos can help.

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Need help to ensure your business stays compliant with the evolving reporting and emerging SAF-T and CTC obligations in Poland?

Keeping up with VAT compliance obligations has become more difficult as Poland continues to take steps to reduce its VAT gap and modernise the system.

Our experts continually monitor, interpret and codify complex legal and technical changes into our software solutions, keeping you up-to-date and reducing the compliance burden on your tax and IT teams.

Learn how Sovos’ solution for JPK_V7M/K, CTC reforms and other VAT compliance changes can help companies stay compliant in Poland and around the world.

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