New SAF-T file applies already from 1 July 2021

On 1 July 2021, new requirements for VAT settlement in JPK_V7 came into force. The exception are regulations related to the e-commerce package and the obligation to mark in the sales register the date of payment or the date of payment in the bad debt relief, which come into force on 1 January 2022.

The changes to JPK_V7 result from the Regulation of the Minister of Finance, Investment and Development of October 18, 2019 on the detailed scope of data contained in tax declarations and records in the field of tax on goods and services, amended on 30 June 2021. The lack of vacatio legis, which is the period elapsing between the date of announcement of the amendment and the date of its entry into force, cannot be assessed positively in this case. It should be remembered that the implementation by taxpayers of even minor changes in the structure of JPK_V7 and in VAT records, as a rule, is associated with a significant organisational, cost and time burden.

Changes resulting from the regulation:

1. possibility to collectively settle simplified invoices up to the amount of PLN 450. This facilitation also applies to invoices documenting a motorway journey or journey in another form, made by taxpayers entitled to provide transport services;
2. change of designation of groups of goods and services (GTU) from “01-13” to “GTU_01-GTU_013” and detailing the list of goods subject to GTU designation;
3. obligation to show in the sales register the date of expiry of the payment deadline or the payment date in connection with the bad debt relief;
4. possibility to mark input tax adjustments with “WEW” if the buyer has not yet received a corrective invoice documenting the event that allows the adjustment;
5. no obligation to use the marking “MPP” for transactions subject to the split payment mechanism in the records of sales and purchases;
6. no necessity to indicate GTU codes for “RO” (collective internal document regarding sales recorded on cash register) and “WEW” (internal document) (internal document), and no need to use additional designations for the code “RO”;
7. no necessity to apply the marking “TP” – for related entities in the case of transactions documenting the receivables exceeding PLN 15,000 in the event that one of the related entities is the State Treasury, a local government unit or association;
8. addition of the indication related to the e-commerce package stating that the taxable person has facilitated via an electronic interface (such as a platform, trading platform, portal or other similar means) the supply of goods or services;
9. replacement of the indications “SW” and “EE” by a single indication “WSTO_EE” – a distance Intra-Community sales of goods and provision of telecommunications, broadcasting and electronic services (from 1 July 2021 until 31 December 2021, the designation “EE” will apply temporarily in this respect) and the addition of the designation “IED” for taxpayers operating electronic platforms that do not use the special procedures for the supply of goods in the national territory;
10. specifying that the name of the consignor or exporter is to be provided on the customs declaration, on the bill of discharge or on the decision and not on the import declaration.

In order to properly prepare for the changes and eliminate doubts related to the new requirements for JPK_V7, we invite you to contact our specialists.

Author:
Maciej Kozub, VAT Specialist (PL)