Obligation to apply new codes in SAFT_VAT (JPK_VAT) starting from the VAT settlement for July 2021

In addition, the Ministry of Finance has announced that they have been working on a new version of the JPK_VAT file, which will be mandatory next year.

The most important changes related to reporting data in JPK_VAT include:

1. Codes "GTU 01-13"– method of assigning GTU codes has been changed from the codes "01" to "13" to codes "GTU_01" to "GTU_13"; additionally, the provisions on the GTU codes has been clarified by referring some of GTU codes to CN codes according to the Combined Nomenclature (CN 2020) and PKWiU codes according to the PKWiU 2015 classification.
2. Exclusion of the application of “GTU” codes to "RO" and "WEW" documents– according to the amended regulations, activities documented with an internal collective document containing sales from cash registers "RO" and an internal document "WEW" will no longer require marking with “GTU” codes.

CHANGES IN „PROCEDURES” CODES

1.  „TP” code – the use of the code "TP" has been excluded in case of supplies of goods and provision of services, when the relations between the buyer and the supplier of goods or the service provider result solely from the relationship with the State Treasury or local government units or their associations.
2.  „MPP” code – the obligation to use "MPP" code has been waived.
3.  „SW” code – the „SW” code has been removed and replaced by „WSTO_EE” code.
4.  „EE” code –  the „EE” code has been removed and replaced by „WSTO_EE” code, however „EE” code needs to be applied (instead of „WSTO_EE” code) in settlements for July 2021 – December 2021 in respect of:

• intra-Community distance sales of goods which, at the time of commencing their shipment or transport, are within the territory of the country (Poland);
• providing telecommunications, broadcasting and electronic services referred to in Art. 28k of the VAT Act, to non-taxable entities with their registered office, permanent residence or place of stay in the territory of a Member State other than the territory of the country (Poland).
• Exclusion of the application of „procedures” codes to „RO” documents – collective internal documents including sale from cash registers „RO” will not require marking with „procedures” codes.

 CHANGES IN „DOCUMENTS” CODES

1. Possibility to collectively show receipts with tax identification number (NIP) up to PLN 450 and single-travel tickets – the possibility of collective reporting of receipts with tax identification number (NIP) up to the amount of PLN 450, issued in accordance with Art. 106e par. 5 point 3 of the VAT Act, and invoices documenting toll motorway travel or travel to any distance, issued in the form of a single-travel ticket by taxpayers entitled to provide services consisting in the transport of passengers by standard-gauge railways, car fleet, sea-going ships, means of inland and coastal shipping, ferries, airplanes and helicopters.

 NEW CODES CONNECTED WITH ENTERING INTO FORCE OF E-COMMERCE PACKAGE

1. Replacing codes "SW" and "EE" with the code "WSTO_EE" – the code "WSTO_EE" has been introduced to apply to both intra-Community distance sale of goods, as well as the provision of telecommunications, broadcast and electronic services, as referred to in Art. 28k of the VAT Act for non-taxable entities with their registered office, permanent residence or place of stay in the territory of a Member State other than the territory of the country (Poland). However, in settlements for July 2021 - December 2021, the code "EE" should be used for intra-Community distance sale of goods and the provision of electronic services to customers from other EU countries.
2. Introduction of the code "IED" – the code "IED" is intended to monitor the supplies of goods referred to in Art. 7a par. 1 and 2 of the VAT Act, which are made by the taxpayer who facilities the supplies and does not use the special procedure referred to in  Section XII Chapter 6a or 9 of the VAT Act or corresponding regulations, for which the place of supply is the territory of country (Poland). The obligation to use the "IED" code will apply starting from the settlements for January 2022.
3. Introduction of the obligation to mark in JPK_VAT that the taxpayer facilitated the performance of the activities referred to in Art. 109b par. 4 of the VAT Act – the taxpayers who are required to submit JPK_VAT, in case they are additionally required to keep the records referred to in art. 109b par. 1 of the VAT Act (in relation to the activities facilitated by them related to the territory of the country, referred to in Article 109b par. 4 of the VAT Act), will have to mark, respectively, in the JPK_VAT declarative part that they have facilitated the activities referred to in art. 109b par. 4 of the Act. This marking obligation will apply starting from the settlement for January 2022.

 OTHER CHANGES IN SAF-T

1. Disclosing the reduction of input VAT referred to in Art. 86 par. 19a of the VAT Act with the use of the document "WEW" – the buyer will be able to use the code "WEW" to report the reduction of input VAT referred to in Art. 86 par. 19a of the VAT Act, if the buyer did not receive a correcting invoice documenting the event before the deadline for submitting JPK_VAT.
2. Obligation to disclose the payment deadline or the date of payment in case of using so‑called "bad debt relief" – this change will apply starting from the settlement for January 2022.
3. Clarification of the provisions on showing data in a customs declaration, a closing declaration or a decision – in case of a customs declaration, a closing declaration or a decision, the full name or the name of the consignor or the exporter should be included, while in case of an import declaration, such data does not have to be provided.

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Due to the entry into force of the new rules for reporting data in the JPK_VAT structure, you should carefully analyze how the changes will affect your VAT settlements and appropriately modify the codes used so far in the JPK_VAT.

At the same time, we would like to point out that as a result of the publication of the Regulation of the Minister of Finance, the previously performed analyzes related to the correct marking of transactions in JPK_VAT may become partially outdated - thus they may require appropriate update.

In case of doubts as to the correct use of codes / showing data in the JPK_VAT structure, please contact Mazars Tax Advisory Department.