WhiteList Poland (WLC PL)

The amendments to JPK_VAT is not the only change to which Polish taxpayers need to adapt. In September 2019, the so-called white list (biała lista) of taxpayers was published by the Polish Ministry of Finance. The white list is an electronic database providing information about taxpayers, such as whether a particular VAT ID is valid. However, taxpayers’ bank account numbers listed in the white list seem to be the most sensitive data.

If a customer makes a payment to a vendor for above 15,000 of Polish zloty, it has to do it into the exact account(s) assigned to a particular vendor, listed on the white list. Otherwise, as of January 2020 serious consequences will apply, both in income and VAT taxation. Customers making a payment to a vendor’s account not indicated on the white list will not be able to include amounts in excess of 15,000 of Polish zloty in deductible costs. From the VAT perspective, customers will be jointly and collectively responsible for the vendor’s VAT liability.

The Ministry of Finance published the so-called API, allowing the white list to be checked directly from the ERP system, for example. However, according to the latest information, it seems that the dedicated API will be turned off in January 2020.

There is an option allowing mass verification of data in the white list. Recently 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.

Considering the level of detail required in JPK_V7M/K and the serious potential consequences arising from non-compliance with the white list, it is recommended to start preparing for the new requirements as soon as possible

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