Polish JPK_VAT files as from July 2020

The new extended SAF-T files (JPK_V7M and JPK_V75 files) will be required in Poland as from July 2020.

Poland will replace VAT returns with an extended SAF-T requirement as from July 2020. This replacement was first announced in 2018 and delayed during 2019. There was an exceptional delay granted this month due to Coronavirus outbreak.

What is the new JPK_VAT file?

The Polish law introduced the new files JPK_V7M for taxpayers submitting monthly VAT returns and JPK_V7K for taxpayers submitting quarterly VAT returns. This is a periodical filing that will replace the existing JPK_VAT files and the VAT return. As a consequence, only one submission (instead of two filings) will be required. However, the new JPK_VAT is a more extensive form which includes classifications of transaction types and codes to identify certain type of goods and services. It is therefore crucial to prepare the new JPK_VAT structure properly, in order to avoid irregularities resulting in penalties.

The Polish tax authorities launched a testing environment on February 28 and will publish additional information and guidelines in April.

Who should file the JPK_VAT file and by when?

The new obligation becomes mandatory as of July 2020 (July reporting period due in August 25th) for large companies and October 2020 (third quarter reporting period due in in October 26th) for medium and small companies.

Taxpayers that employ more than 250 people and have a turnover in excess of EUR 50 million, as well as those that employ more than 250 people and have total assets in excess of EUR 43 million are considered as large taxpayers. Companies that do not meet these requirements should be considered medium/small companies and will fall under this obligation in a later stage.

Frequency of filing and deadlines

The JPK_VAT file should be filed by the 25th day of the month following the reporting period (monthly or quarterly). If the 25th day is a Saturday or bank holiday, the due date is extended until the next business day.

Additional information to be reported in the JPK_VAT file

According to the new specifications, taxpayers will be required to report specific codes to classify the good or service rendered. These codes are not related to Combined Nomenclature (CN) codes or to the Polish statistical classification.

Also, document types to identify certain transactions and type of documents should be also reported.

This overview includes a list of codes to be assigned.

What are the applicable penalties?

The Polish VAT law foresees fines of 500PLN for each error in the JPK_VAT file. Errors in the JPK_VAT filed notified by the authorities should be corrected within two weeks.

Get help with the new Polish JPK_VAT files

You should evaluate if all required information is available in your system. You would then carry out a data validation and data mapping exercise to make sure that the right data is in the right format. Once done, you should ensure that you are capable of transmitting the file to the Polish tax authorities according to local requirements.

Marosa has vast experience in this set up project and we will be happy to help you adapting your systems and transmitting JPK_VAT. Contact us to start the process of compliance with Polish law.

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