White List – money transferred to the wrong account

January 30, 2023

The so-called White List, i.e. the official public register of VAT taxpayers kept by the Head of the National Tax Administration, officially entered into force on September 1, 2019. From 2020, the lack of verification of contractors based on the White List may have negative consequences in the area of ​​taxes.

What is the White List?

The White List includes, among others, the following data::

  1. business name (name of the company) or names and surnames in the case of sole proprietors
  2. business address
  4. the date of registration for VAT purposes, as well as the date of removal from the register of VAT taxpayers
  5. the status of the entity for VAT purposes – “active VAT payer” / “exempt VAT payer”
  6. bank account numbers reported to the tax office

The last two points (5 and 6) are the most important from the perspective of tax settlements. Checking the status of the contractor for VAT purposes may be crucial in terms of the right to deduct input tax, and consequently affect the correctness of VAT settlements.

White List and money transfer to the wrong account

It is equally important to verify the contractor’s bank account to which we want to make the payment. If we make a transfer to a bank account that has not been shown on the White List, then – as a rule – we cannot include such an expense as tax deductible costs. In addition, we may be jointly and severally liable for VAT with the supplier. The only “rescue” in such a situation is to send a notification on the ZAW_NR form to the relevant tax office. The deadline for submitting this notification is 14 days from the date of making the transfer

Important: for evidence purposes, it is good to keep confirmation of the counterparty’s account verification on the White List

Who is released from the obligation to transfer money to a whitelisted account?

The obligation to pay to an account on the White List does not apply to::

  • Transactions where neither party is an entrepreneur
  • Transactions between entrepreneurs in which the one-off value of the transaction, regardless of the number of payments resulting from it, exceeds PLN 15,000 gross or the equivalent of this amount (in the case of transactions in foreign currencies)
  • Compensation and barter, even if they exceed PLN 15,000 gross, i.e. non-cash settlements.

The White List is updated daily to provide taxpayers with the best source of information.

Where to find the White List?

Link to the White List can be found below:


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