Aleksandra Majnusz

Steuerberaterin (Polen)
Senior Associate
Phone: + 48 32 330 12 27

The authorities are planning to introduce new Standard Audit File for Tax structures in 2020, namely: JPK_V7M to be filed monthly and JPK_V7K to be filed quarterly. They will replace the current JPK_VAT (SAF-T VAT) and VAT returns.  All details that will have to be disclosed in those files are set out in the regulation of the Minister of Finance, Investment and Development of 15 October 2019 (published on 18 October 2019) on the detailed scope of data to be disclosed in tax returns and value added tax records.

Large enterprises will have to follow the new regulations from 1 April 2020 and others (micro, small and medium-sized enterprises) from 1 July 2020.

Changes to the VAT SAF-T structure entail changes to sales records, which, in addition to what they already show, will have to include:

  • symbols of supplies of certain goods and services;
  • symbols of transaction types;
  • symbols of evidence of sale.

In contract to sales records, purchase records will not have to show special symbols of purchases of individual goods or services. However, you will be obliged to:

  • label evidence of purchase;
  • label input tax.

The above changes will require modification of the accounting software used for recording sales and purchases and for generating SAF-Ts. You may need to:

  • identify the reported data;
  • implement new functionalities in your finance/accounting software;
  • add a functionality to import data from sales and invoicing systems;
  • develop solutions to check internally if the reported data are correct.

If you submit a SAF-T which includes errors or inaccurate data, tax authorities may fine you up to PLN 500 for each detected irregularity. 

 Before imposing the penalty, tax authorities will call upon you to submit amended records and will indicate the errors or inaccurate data.  If you submit amended records with the errors and inaccuracies rectified within 14 days of the authorities’ request, the fine will not be imposed. No fine will be imposed in respect of the error fixed by the amendment. 

The fine of PLN 500 will not be imposed on sole proprietors, who are liable for such wrongdoings as for fiscal offences or fiscal crimes.

Here are details about additional symbols and labels of supplies, transactions and documents:

Table 1 Sales records – symbols of supplies of certain goods and services

Name of goods or services Mandatory symbol
alcoholic beverages – ethyl alcohol, beer, wine, fermented beverages and intermediate products in the meaning of excise duty laws 01
goods referred to in Article 103(5aa) of the VAT Act (e.g. diesel oils coded CN 2710 19 43, CN 2710 20 11) 02
heating oil in the meaning of excise duty laws and lubricating oils, other oils CN-coded from 2710 19 71 to 2710 19 99, except products code 2710 19 85 (white oils and liquid paraffin) and grease lubricants (CN 2710 19 99), lubricating oils CN 2710 20 90, lubricating preparations CN 3403, excluding grease lubricants included in that code 03
tobacco products, dried tobacco, electronic cigarette liquids and innovative products in the meaning of excise duty regulations 04
wastes – exclusively those listed in items 79-91 of annex 15 to the VAT Act 05
electronic devices and their parts and materials, exclusively those listed under items 7-9, 59-63, 65, 66, 69 and 94-96 of annex 15 to the VAT Act 06
vehicles and car parts, exclusively those coded CN 8701-8708 and CN 8708 10 07
precious metals and base metals, exclusively those listed under items 1-3 of annex 12 and items 12-25, 33-40, 45, 46, 56 and 78 of annex 15 to the VAT Act 08
medicines and medical devices – medicinal products and foodstuffs for special nutritional purposes as well as medical products that are subject to registration referred to in Article 37av(1) of the Pharmaceutical Act (Journal of Laws of 2019, item 959 as amended) 09
buildings, structures and land 10
services related to the transfer of greenhouse gas allowances referred to in the act on greenhouse gas emission allowance trading scheme 11
intangible services: exclusively consulting, accounting, legal, management, training, marketing, head offices, advertising, market research and public opinion polling, scientific research and development work 12
transportation and warehouse management services – section H of Polish Classification of Goods and Services 2015, symbol ex 49.4, ex 52.1 13

Table 2 Symbols of transaction types

Transaction name Mandatory symbol
mail order sale from Poland SW
telecommunications, broadcasting and electronic services referred to in Article 28k of the VAT Act EE
transactions involving relations between the buyer and supplier of goods or services referred to in Article 32(2)(1) of the VAT Act TP
intra-Community acquisition as part of a triangular transaction following a simplified procedure (effected by the second-in-turn taxpayer) TT_WNT
supply of goods outside Poland as part of the simplified triangulation procedure (effected by the second-in-turn taxpayer) TT_D
supply of tourist services accounted for in the margin procedure MR_T
supply of used goods, works of art, collector's pieces and antiques accounted for in the margin procedure MR_UZ
intra-Community supply of goods after the goods have been imported in the Code 42 Customs Procedure (import) I_42
intra-Community supply of goods after the goods have been imported in the Code 63 Customs Procedure (import) I_63
transfer of a single-purpose voucher made by a taxable person acting in his own name B_SPV
supply of goods or services for which a single-purpose voucher has been issued for a taxable person who has issued that voucher B_SPV DOSTAWA
agency services and other services related to the transfer of a multi-purpose voucher B_MPV PROWIZJA
transactions subject to split payment mechanism MPP

Table 3 Sales records – labels of evidence of sale

Nama of evidence of sale Mandatory symbol
internal collective document containing sales recorded on cash registers RO
internal document WEW
invoice referred to in Article 109(3d) VAT Act FP

Table 4 Purchase records – labels of evidence of purchase

Name of evidence of purchase Mandatory symbol
invoice issued by a taxable person being a supplier of goods or services, who has chosen the cash accounting method referred to in Article 21 of the VAT Act MK
VAT RR invoice referred to in Article 116 of the VAT Act VAT_RR
internal document WEW

Table 5 Evidence of purchase – symbols of input tax

Type of input tax Mandatory symbol
on import of goods, including import of goods accounted for in line with Article 33a of the VAT Act  
on transactions subject to mandatory split payment MPP

If you have any doubts about the new SAF-Ts for VAT, Rödl & Partner's experts in Cracow, Gdansk, Gliwice, Poznan, Warsaw or Wroclaw will be glad to help you.

Przemysław Trzaska,