Poland SAF-T: JPK VDEK, JPK VAT and other JPK files
The Uniform Control File (JPK) is a set of data, generated from a business entity’s IT systems (by direct data export), which contains information about business operations for a given period. Poland JPK has a specific layout and format (XML schema). It is sent only in electronic version.
New JPK_VAT with the declaration (JPK_VDEK)
(For periods starting from 1 October 2020 for all taxpayers)
The government has recently announced final requirements for a new SAF-T document for VAT Returns that was called JPK_V7M(2) and JPK_V7K(2). New version of file structures will be effective from January 2022. Taxpayers in Poland will no longer submit a separate JPK_VAT information and a separate VAT declaration (VAT-7 or VAT-7K). From 1 October 2020, they must submit one file, JPK_VAT with declaration, which contains data of both VAT declaration and transactional VAT records. With the use of JPK_VDEK, there will be no need to generate two files, place two authorization signatures, make two shipments and wait twice for UPO.
Two JPK_VAT variants will apply:
JPK_V7 M – for taxpayers who pay VAT monthly and
JPK_V7 K – for taxpayers who pay VAT quarterly.
Changes in new JPK_V7
The basis for the changes in JPK_V7 is the introduction of new e-commerce rules on the EU side. Changing fields; WSTO_EE, IED, MPP, and bad debts. WSTO_EE changed in EE and SW indicators and must be allocated for intra-community distance goods sales and electronic service provision. Next new field is IED assigned for supplies by e-commerce platforms.
These change is not an additional new field, its about a removal of MPP indicators. Because the obligation to indicate the transactions subject to the compulsory split payment mechanism was removed. In the final structure the new JPK_V7 file no longer has MPP indicators on both the sales and purchase parts.
Additionally P_560 field that must be marked by taxpayers who apply for a VAT refund within 40 days. The given VAT return period is one of the advantages of applying the e-Invoice(KSeF) system voluntarily.
The start of using the new version of JPK_V7 is scheduled for 25 February 2022. Considering that the amendments to the final version were made on 27 December 2021, companies do not have much time to implement new requirements for their IT solutions. Therefore, it is worth reminding that changes need to be implemented immediately by Polish VAT taxpayers.
Submission deadlines
New JPK_VAT will be submitted in monthly periods, up to the 25th day of the month for the previous month (unless the 25th day of the month falls on a Saturday or a public holiday, then you have time to the first business day).
Example of monthly settlement – version JPK_V7M
JPK_VAT for January – the entrepreneur will send by February 25
JPK_VAT for February – the entrepreneur will send by March 25
JPK_VAT for March – the entrepreneur will send by April 25
Example of quarterly settlement – version JPK_V7K
JPK_VAT only the record part for January-the entrepreneur will send by February 25
JPK_VAT only the record part for February – the entrepreneur will send by March 25
JPK_VAT the record part for March and the declaration part for January, February and March – the entrepreneur will send by April 25
Mandatory Fields
JPK_V7M – for taxpayers who are required to submit record and declaration parts monthly. Taxpayers are required to complete all JPK_V7M elements in an XML file, i.e. Naglowek, Podmiot1, Deklaracja, SprzedazWiersz, SprzedazCtrl, ZakupWiersz, ZakupCtrl.
JPK_V7K – for taxpayers who are required to submit a registration part monthly, and declarative one quarterly. Taxpayers in JPK_V7K for the first two months of the quarter should complete the following elements in an XML file, ie .: Naglowek ( except for: Kwartal, KodFormularzaDekl, WariantFormularzaDekl), Podmiot1, SprzedazWiersz, SprzedazCtrl, ZakupWiersz, ZakupCtrl.
However, for the third month of the quarter they should fill in all JPK_V7K elements in an XML file, i.e. Naglowek, Podmiot1, Deklaracja, SprzedazWiersz, SprzedazCtrl, ZakupWiersz, ZakupCtrl,
Attention:
In submitted corrections, only parts (declaration or records, respectively) which are subject to correction are filled in:
- In case of correction on declaration and records parts all elements are indicated, i.e.: Naglowek, Podmiot1, Deklaracja, SprzedazWiersz, SprzedazCtrl, ZakupWiersz, ZakupCtrl
- In case of correction only declaration part which has no effect on the record part, the following elements shall be indicated: Naglowek, Podmiot1, Deklaracja
- In case of correction only part of the record which does not affect the declaration part, indicate the elements: Naglowek (JPK_V7M – without the item KodFormularzaDekl, VariantFormularzaDek; JPK_V7K – without the Kwartal element, FormFormDecode, FormFormDeclector), Podmiot1, SprzedazWiersz, SprzedazCtrl, ZakupWiersz, ZakupCtrl.
Other details
New JPK_VAT will apply only for tax settlements made so far in the form of declarations VAT-7 and VAT-7K. However, it will not apply to other tax declarations to which the current regulations will apply (e.g. VAT-12, VAT-8, VAT-9M, VAT-10 or VAT-14 declarations)
JPK_VAT (The Old Version)
(Eligible for periods up to September 30, 2020 and corrections for these periods)
What is JPK_VAT?
It is a set of information about purchases and sales, which results from the entrepreneur’s VAT records for a given period. The data shown in JPK_VAT should be consistent with the data included in the VAT declaration.
Who submits JPK_VAT?
All registered VAT taxpayers. This obligation applies to you if you are a VAT payer and submit, inter alia, VAT-7 or VAT-7K declarations.
When to submit JPK_VAT
Information on the records kept in the form JPK_VAT is submitted without a request by the 25th day after the end of a given month (unless the 25th day of the month falls on a Saturday or a public holiday, then you have time to the first business day). If you have been using the quarterly method so far, you will also send JPK_VAT every month.
E.g:
by February 26 you will send information for January (because February 25 is Sunday)
by March 26 you will send information for February (because March 25 is Sunday)
by April 25 you will send information for March etc.
You can request to postpone the JPK_VAT submission deadline. Submit a reasoned request before the deadline for submitting JPK_VAT to the head of tax office competent for you.
Other JPK files (to be submitted on-request)
- JPK_KR (Accounting books)
- JPK_WB (Bank statements)
- JPK_MAG (Warehouse/Storage)
- JPK_FA (VAT invoices)
- JPK_PKPIR (Revenue and expense tax books)
- JPK_EWP (Revenues registry)
From July 1, 2018, all taxpayers who keep tax books and generate accounting documents in electronic form, transfer JPK structures at the request of tax authorities.
The tax authority may request the transfer of JPK as part of:
- tax control
- checking activities,
- customs and tax control,
- tax proceedings.
The tax authority may request JPK:
- from the taxpayer,
- from a contractor if he maintains tax books in electronic form.
How much time is required to provide JPK on request
If the tax authority requests you to transfer one or several of the JPK structures, you will have at least 3 days to transfer them. The exact date will be specified in the call.
In justified cases (e.g. large amounts of data, absence of a responsible person) you can ask the tax authority to extend this period. This will allow you to avoid the consequences if you do not deliver the files within the prescribed period.
+ How SNI SAP-add on will ease life with these documents?
SNI add-on will automatically retrieve accounting data from your SAP modules. It will create an electronic JPK_VAT document within your SAP. Then, it enables sending documents to the tax authority through a connector without manual download/upload. Eventually it will make the taxpayer stay compliant, it will ease the business processes while keeping client’s data secure by not extracting it out of SAP.
