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).
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.
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_EWP for revenue account
JPK_KR for accounting books
JPK_MAG for warehouses
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.
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
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.
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.
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