This new requirement – referred to as JPK_VAT – essentially includes two parts: an extension to the previous SAF-T (which stands for Standard Audit File for Tax) and the Polish VAT return, merged into a single improved SAF-T return.
The deadline to submit this new version of SAF-T to the Polish tax agency for the first time is 25 November 2020, and this first return should cover October 2020 data.
What has changed?
Condensing the submission into a single return
Up until 25 October 2020, Polish VAT submissions consisted of two separate VAT reporting requirements: an existing SAF-T (or audit file), and the VAT return (VAT-7).
Both reporting requirements have now been merged and the return extended with new fields to allow the submission of a single return.
This relieves taxpayers from having to complete more than one form which reduces the pressure on companies.
A partial aim for this implementation is to increase protection against Polish tax fraud. However, this simplification serves as a benefit in other ways too. Each VAT settlement will be automatically verified in terms of the correctness of the reported amounts of due and input tax, without involving the taxpayer.
Additional data requirements from the new return
The new SAF-T structure will involve not only specification of goods and services but also appropriate group codes (referred to as GTU codes). This means that taxpayers will be expected to appoint specific codes to certain transactions.
For example, distance sales of goods within Poland should be codes as ‘SW’.
In order to classify their taxable transactions, taxpayers will need to refer to various sources, including:
- the Polish Classification of Goods and Services
- Combined Nomenclature
- VAT Act along with Annex 15 (listing goods and services covered by the split payment mechanism)
- Excise Duty Act, but also provisions of the Pharmaceutical Law (for medicinal products or medical devices, the register of which is periodically updated by the Ministry of Health by way of notice).
What is not changing?
The filing deadline for the new SAF-T return will remain the 25th day of the month following a VAT period.
The new SAF-T will consist of all the information previously required in the old SAF-T but will be extended with additional fields to allow reporting of further information.
Fines resulting from mistakes
Please note that if the tax authorities find an error in a taxpayer’s SAF-T format, they can impose a fine of PLN 500 for each error. The fine may be waived if, within the specified deadline, the taxpayer makes corrections.