As from 1 July 2016 some VAT taxpayers in Poland will have to comply with an additional reporting requirement, i.e. to produce a file detailing specific information about the business of the taxpayer to provide it electronically to the Polish tax authorities for audit purposes upon their request.
This file will need to be provided in a specific format defined by the Polish tax authorities and thus is called Standard Audit File for Tax (SAF-T) or in Polish, Jednolity Plik Kontrolny (JPK).
The VAT taxpayers which will be first asked to put together and provide the JPK to the Polish tax authorities are taxpayers whose personnel exceeds 250 employees and whose yearly turnover exceeds EUR 50´000´00, irrespective of whether they are established in Poland or not. This has been explicitly confirmed in the final version of the regulation introducing JPK into the Polish tax legislation, i.e. foreign businesses not having any presence in Poland (i.e. branch and/or fixed establishment) but being registered for VAT in Poland by reference to the nature of their supplies also fall within the scope of the above reporting requirement, provided that the size of their business meets the above conditions.
Specifically, JPK needs to include the following information:
- Accounting books;
- Bank statements;
- Warehouses (receipt, release and internal movement transactions);
- VAT evidence (details of the sales and purchases);
- VAT invoices;
- VAT revenue and expense ledger;
- Records of revenues.
It is expected that the first requests to put together and provide JPK will be made by the Polish tax authorities in September 2016.
Other taxpayers (i.e. having more than 9 employees and turnover exceeding EUR 2´000´000) will fall within the scope of the above regulation from 1 July 2018.
Conclusion and recommendation for actions
Bearing in mind that the first requests for JPK will be sent out in September 2016, there is still some time to prepare for both groups of taxpayers (i.e. for those who can receive the request for JPK post 1 July 2016 as well as for those who may receive it post 1 July 2018).
Specifically, the taxpayers should undertake a review of their systems and the quality of the data that they can currently extract from their systems and map it to the requirements of JPK to identify the level and/or lack of compliance with the above regulation.