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Poland Whitelist (Biała Lista)

What is the Polish White List?

The electronic database of VAT-registered taxpayers in Poland.


What does the Polish White List database contain?

The electronic VAT database contains contractors’ information such as business name, address, VAT number, VAT registration status, and date of registration. In addition, it contains the bank account numbers reported to the tax office by all taxpayers (through the submission of the NIP-8 or NIP-2 tax forms).


What is the function of the register?

The e-register makes it possible for a vat payer registered in Poland to check their contractor’s VAT status and bank account information. This is useful for defending an input VAT deduction effectively and carrying out due diligence in case of a VAT fraud.


What is the obligation date for the Polish White List?

This will come into effect on 1 September 2019. However, there is no explicit obligation for taxpayers to verify contractors’ bank accounts through the White List. But the new rules impose an obligation to execute bank transfers using bank accounts listed in the e-register in respect of all business-to-business transactions exceeding PLN 15,000, including VAT.


Sanctions for not complying with the Polish White List 

The sanctions for making payments to bank accounts not listed in the e-register (at the date of the bank transfer order) came into force on 1 January 2020.


  • For VAT: there will be joint responsibility for output VAT not settled by the supplier (up to the VAT amount on the invoice);
  • For income taxes: the expenditure will not be treated as tax deductible.

How can you avoid sanctions?


The sanctions can be avoided in two situations: 

  • when making a split payment transfer (only VAT joint responsibility sanction will be canceled), and; 
  • when a notification (providing details of the bank account to which the payment was made) is submitted to the tax office within 3 days of the bank transfer.


Is mass verification possible?


There is an option allowing the mass verification of data in the White List. The Ministry of Finance published a specification of the so-called “flat file”. The flat file, updated daily, contains encrypted data about bank accounts assigned to particular VAT IDs (or NIP, using the Polish acronym). Therefore, the flat file will only allow the verification of whether particular pairs of VAT IDs and account numbers are present in the White List. It will not be possible to, for example, look up bank account numbers using company names.


How can SNI help customers to comply with the Polish White List?


The SNI add-on solution helps you to check the White List’s daily updates made by the Polish tax authority. SNI uses the flat file method to complete these checks. The SNI add-on solution helps you to extract master data information for Polish VAT numbers and bank accounts, and check the situation of taxpayers from the government’s White List. It also allows you to impose or release payment blocks, both manually and automatically. This check can also be automated using the batch job setting. 

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