The Polish Ministry of Finance has published a regulation in the Journal of Laws detailing the structure of the new JPK_VAT standard audit file (labelled up to now with the title “JPK_VDEK”), filing of which will become mandatory for large taxpayers from 1 April 2020 and for small and medium taxpayers from 1 July 2020.
Taxpayers filing monthly will submit version JPK_VAT7M, whilst those filing quarterly will instead submit version JPK_VAT7K. The regulation details the data requirements of the file, in particular:
1. Since JPK_VAT will incorporate the elements of the existing periodic VAT-7 and VAT-7K returns, a taxpayer’s obligation to file those returns will disappear once they commence filing JPK_VAT
2. Additional settlement data, including an indication that the taxpayer:
- applies for the tax refund to be credited towards future tax liabilities;
- provided services defined as those of a tour operator;
- traded in second-hand goods, antiques or works of art;
- traded in investment gold;
- was a party to an Intra-Community supply of goods using the triangulation
- is entitled to a reduction in the amount of VAT payable due to paying it early;
- is making an adjustment due to unpaid bad debts
3. A series of markings making it easier to identify transactions in certain types of goods and services (e.g. those mentioned in 2. above; excise goods; vouchers; distance sales; and those previously treated as subject to the domestic reverse charge VAT regime). The apparent purpose of these markings is to facilitate the tax authority’s review of these transactions in the course of their routine tax inquiries.