The time has come for a new JPK_VAT, i.e. JPK_V7M and JPK_V7K. Why should you prepare today?
What is the new JPK_VAT file?
Depending on the chosen VAT settlement method (monthly settlements – JPK_V7M, quarterly settlements – JPK_V7K), it is a joint file that includes data from both the register and the VAT return.
For which period should the first new JPK_VAT file be sent?
For so-called “large” taxpayers, the obligation to send new JPK files starts effect from the VAT settlement for April 2020, so the new JPK file needs to be sent by 25th May. There is no need to send the JPK_VAT file and declaration separately. “Large” entrepreneurs are those with over 250 employees and turnover exceeding EUR 50 million, or with over 250 employees with the sum of balance sheet assets exceeding EUR 43 million.
Every taxpayer will be obliged to send the new file from the VAT settlement for July 2020 – the file should be submitted by 25th August.
New scope of data in the VAT records
Aside from combining the VAT register with the VAT return, the new JPK_VAT contains many additional and relevant data, including:
• New codes of sensitive goods (1-10) and services (11-13),
• Transaction codes (e.g. mail order, electronic services, three-party transactions, chains, MPP, vouchers),
• Designation of document types (FP, RO, WEW, VAT_RR, MK),
• Additional information on intangible services (GTU_12).
It should be noted that currently taxpayers do not possess this data in their tax and accounting systems. The new data allows an easier and more accurate way to analyze and control taxpayers’ ongoing settlements. Among others, the new data enables the identification of chain transactions, mail order sales and even transactions using the call-off stock procedure or fall within the scope of the mandatory split payment mechanism. Until now, such data analysis has not been possible.
As a result of the upcoming amendments the scope of data presented in the new JPK_VAT file will be significantly extended. It is crucial to prepare the new JPK_VAT structure properly, in order to avoid irregularities in VAT liability calculation and any resulting penalties.
New penalties for errors in JPK_VAT
In addition, a new sanction of PLN 500 has been introduced for each error in the JPK_VAT file which prevents the tax authorities from verifying the correctness of a transaction (taxpayers will have 14 days to correct errors after they are called upon to do so). For example, if the JPK_VAT file involving the delivery of electronics is not marked with the GTU_06 code, and 300 such deliveries took place, the applicable penalty can be as much as PLN 150,000.
Moreover, additional penalties will also be implemented in the Polish Penal Fiscal Code. According to new provisions, if the taxpayers do not meet statutory deadlines when filling JPK_VAT files or send the files containing mistakes or inconsistencies with the facts, the persons responsible for the tax matters will be fined with penalties up to 240 daily rates (maximum of 6.720k PLN). Please note that penalties resulting from the Penal Fiscal Code will remain valid even if the data is corrected properly after the request of the tax authorities.
Therefore, it might be expected that any mistake, including typos and other unintended mistakes, may result in imposing the penalties.
How can we help you?
SSW’s competence and experience can help you to prepare a new JPK_VAT, file both as regards the content and technical issues. Our services include the following:
• Reviewing existing JPK files and their mapping in order to eliminate potential irregularities.
• Preparing tax processes to ensure that the required data is included in your VAT records.
• Mapping your system to indicate which data should be supplemented with additional fields in the records.
• Preparing a system/application for generating a JPK file in the JPK_V7M / JPK_V7K version.
Please contact us if we can help with any of the above or with any other issues you may have in relation to new or old JPK files.
