What will we face? – new JPK_VAT with the declaration, 2020
March 2, 2020
At the beginning of February, the Ministry of Finance published a brochure concerning JPK_V7M and JPK_V7K. We are going to analyze what results from it and how to prepare for incoming changes.
What is JPK_VAT with a declaration?
JPK_VAT with the declaration is an electronic document that will combine two parts which have been reporting so far separately:
• VAT records (current JPK_VAT) – a set of information about purchases and sales, which results from entrepreneur’s VAT records for a given period
• VAT declaration – VAT-7 and VAT-7K declaration,
as well as additional data that is needed to analyze the correctness of settlement.
Sales records will also have to include:
• specification of the types of certain goods and services
• specification of the types of transactions
• specification of the proof of sales
Purchase records will also have to include:
• specification of the proof of purchase
• specification of certain transactions that are subject to specific VAT procedures – import of goods, transactions being subject to the obligation of applying the split payment mechanism.
Why this change? Data from the new reporting method are primarily to be used for more precise control and analytical purposes conducted by the Head of KAS – in accordance with the justification to the introductory law.
OBLIGATORY CODES
These additional codes, which will apply to JPK_V7M and JPK_V7K, are necessary. The codes cannot be underestimated, if only because of fines.
You should pay special attention to this while invoicing. Thus, the greatest responsibility lies with entrepreneurs to correctly assign the indicators to goods sold and services rendered, which goes hand in hand with coding already at the invoicing level. Proofs of sale and purchase are also important, as indicated by other mandatory indicators. The following tables will clear up the doubts.
SALES RECORDS:
indicators identifying the delivery of individual goods and rendered services
| Name of goods or services | Obligatory code |
| alcoholic beverages – ethyl alcohol, beer, wine, fermented beverages and intermediate products within the meaning of the provisions on excise duty | 01 |
| goods referred to in art. 103 paragraph 5aa of the amended act (e.g. diesel oils with codes CN 2710 19 43, CN 2710 20 11) | 02 |
| heating oil within the meaning of the provisions on excise duty and lubricating oils, other oils with CN codes from 2710 19 71 to 2710 19 99, excluding products with CN code 2710 19 85 (white oils and liquid paraffin) and plastic greases falling within CN code 2710 19 99, lubricating oils with CN code 2710 20 90, lubricating preparations falling within CN 3403, excluding plastic lubricants falling within this position | 03 |
| tobacco products, dried tobacco, liquid for electronic cigarettes and innovative products within the meaning of the provisions on excise duty | 04 |
| waste – only specified in position 79-91 of Annex 15 to the VAT Act | 05 |
| electronic devices and parts and materials therefore exclusively specified in positions: 7-9, 59-63, 65, 66, 69 i 94-96 of the Annex 15 to the VAT Act | 06 |
| vehicles and car parts falling only within codes CN 8701-8708 and CN 8708 10-8708 09 | 07 |
| precious and base metals – only specified in positions: 12-25, 33-40, 45, 46, 56 and 78 of Annex 15 to the VAT Act and in positions: 1-3 of Annex 12 to the VAT Act | 08 |
| medicines and medical products – medicinal products, foodstuffs for particular nutritional uses and medical products, covered by the obligation to notify referred to in art. 37av paragraph 1 of the Act of 6 September 2001 – Pharmaceutical Law (Journal of Laws of 2019, item 959, as amended) | 09 |
| buildings of structures and grounds | 10 |
| mail-order trade from the territory of the country | SW |
| services for the transfer of greenhouse gas emission allowances | 11 |
| intangible services: exclusively: consultancy, accounting, legal, management, training, marketing, head offices, advertising, market and public opinion research, in the field of scientific research and development works | 12 |
| transport and storage management services – section H PKWiU 2015 symbol ex 49.4, ex 52.1 | 13 |
| telecommunications, broadcasting and electronic services | EE |
| transactions where there are links between the buyer and the supplier of goods/services | TP |
| WDT (intra-community delivery of goods) as part of the procedure of „call-off stock” | CS_WDT |
| WNT (intra-community acquisition of goods) as part of the procedure of “call-off stock” | CS_WNT |
| delivery of goods as part of a chain transaction | TL |
| WNT (intra-community acquisition of goods) as part of a three-party transaction in a simplified procedure | TT_WNT |
| delivery of goods outside the territory of the country under a three-party transaction under the simplified procedure | TT_D |
| delivery, intra-community acquisition of investment gold | AU |
| provision of tourism services, taxed on the basis of a margin | MR_T |
| supply of used goods, works of art, collectibles and antiques, taxed on the basis of a margin | MR_U,Z |
| WDT (intra-community delivery of goods) following the import of these goods under procedure 42 (import) | I_42 |
| WDT (intra-community delivery of goods) following the import of these goods under procedure 63 (import) | I_63 |
| transfer of a single-purpose voucher made by the taxpayer acting on his own behalf | B_SPV |
| supply of goods or services that are subject to the single-purpose voucher to a taxable person who issued the voucher | B_SPV DOSTAWA |
| brokerage and other services concerning transfer of the multi-purpose voucher | B_MPV PROWIZJA |
| transactions covered by the split payment mechanism | MPP |
Indicating proofs of sale
| Name of the proof of sale | Obligatory code |
| internal summary document containing sales from cash registers | RO |
| internal document | WEW |
| Invoice issued according to rules defined in Art. 106b item 3 of the VAT Act (issued on the buyer’s request) | FP |
| Invoice issued by the taxpayer who chose the cash settlement method | MK |
| customs declaration or import declaration referred to in Art. 33 b of the VAT Act documenting the import of goods accounted for in accordance with Art. 33a of the VAT Act | IMP_33a |
| Invoice covered by the split payment mechanism | MPP |
PURCHASE RECORDS
Purchase records will not have separate indicators defining the purchase of individual goods or services. However, there will be an obligation introduced to mark the proof of purchase appropriately.
| Name of the proof of purchase | Obligatory code |
| invoice issued by the taxpayer being the supplier who chose the cash settlement method | MK |
| VAT RR invoice | VAT RR |
| Invoice from the taxpayer who is settle on the basis of the lump sum | TX |
| duplicate invoice | DF |
| Internal document | WEW |
| Simplified invoice | FU |
| invoice covered by the split payment mechanism | MPP |
When? – deadlines for JPK_V7M and JPK_V7K
New JPK_VAT will be submitted by taxpayers registered as active VAT payers for the following periods:
- from April 1, 2020 – obligatory for big enterprises, other enterprises voluntarily,
- from July 1, 2020 – obligatory for all taxpayers (big, medium and small enterprises and micro enterprises).
However, it should be emphasized that if small, medium enterprises and micro-entrepreneurs take advantage of the voluntary option of submitting a new JPK_VAT for the periods from April 1, 2020, they will not be able to return to the settlement on previous terms.
NOTE: From July 1, 2020 it will not be possible to submit VAT-7 and VAT-7K declarations otherwise than via JPK_V7M / JPK_V7K.
Technically about JPK_V7M i JPK_V7K
The taxpayer prepares and then sends one file that will combine registration and declaration parts (items from current VAT-7 / VAT-7K declarations).
Attachments that appeared in previously sent declarations will be replaced with check boxes contained in the new reporting file.
The new JPK_VAT will be submitted electronically for monthly periods, up to the 25th day of the month for the previous month (unless the 25th day of the month falls on Saturday or a public holiday, then the time is extended to the next business day).
Of course, the quarterly settlement was not omitted, because two variants of the new JPK_VAT were prepared:
• JPK_V7M – for taxpayers who settle on the monthly basis
• JPK_V7K – for taxpayers who settle on the quarterly basis.
Signing a new file will be allowed with:
• qualified signature (Polish or other EU country),
• trusted profile,
• authorization data.
After the whole process is completed with submission of a correct JPK_V7M or JPK_V7K, the taxpayer will be able to download the Official Receipt Certificate (UPO).
Separately, apart from the new JPK, taxpayers will still be required to submit:
• VAT EU
• VAT-9M, VAT-8, VAT-11, VAT-12, VAT-13, VAT-21, VAT-23.
Sanctions?
Changes will also take place in the legal liability rules. This shows how important it is for tax authorities to obtain data from JPK_V7M and JPK_V7K. Financial penalties of PLN 500 will be applicable for any mistake in records that prevents verification if a transaction is correct, when there is no correction or clarification within 14 days.
Examples of punishable errors: incorrect sales date format or entering the supplier’s NIP number in the field provided for the proof of purchase number.
How can entrepreneurs prepare for new requirements?
To make the entry into force of JPK_V7M / JPK_V7K less problematic, it is important to prepare for changes in advance:
• implementation of appropriate functions in financial and accounting systems
• analyzing and identifying data that undergo raporting
• establishing solutions to check the correctness of reported data
• internal system for efficient error correction
The Ministry of Finance is reaching out to taxpayers because by the end of February 2020 it plans to launch a test environment for: JPK_V7M (for taxpayers who pay monthly) and JPK_V7K (for taxpayers who pay quarterly). The purpose of providing the test environment is to verify the correctness of operation of the new API gateway.
To sum up, after analyzing the new JPK_VAT – the scheme and consequences for the taxpayer, the main conclusion comes: patience and perseverance. That is what we wish you and us!
Author: Katarzyna Zawolska
Tags JPK changes in 2020 Poland, JPK VAT 2020 codes, JPK with the declaration, taxes in Poland, vat
