New structure of JPK_VAT with declaration from July 2020

Structure of the uniform control file JPK_V7 - new elements and the date of entering into force

The obligation to submit declarations in the form of a JPK V7 file was initially intended to be introduced in two stages, taking into account the size of a company. However, due to the state of the coronavirus epidemic, the Ministry of Finance has set one final date for all economic entities.

The new structure of the JPK_VAT scheme with a declaration in the form of JPK_V7 enters into force on 1 July 2020, with the JPK V7 file being available in two variants - JPK_V7M and JKP_V7K.  The choice of the appropriate variant will depend on the form of settlements used by a given enterprise:

• JPK_V7M for monthly settlements (deadline for submission for the previous month by the 25th day of the following month),
• JPK_V7K for quarterly settlements (deadline for submission for the previous month by the 25th day of the following month; for the first two months of the quarter the bookkeeping part and for the third month the bookkeeping and declaration part)

The files will be sent only electronically and will bear qualified signatures, trusted profiles or authorisation data.

Moreover, JPK V7 will contain a set of detailed data on purchase and sale transactions, and the file itself will be divided into two parts:

• Declaration part - including the items previously presented in VAT returns, e.g. VAT-ZZ, VAT-ZD, VAT-ZT and VAT-ZT attachments and applications for VAT refunds and bad debts relief,
• Bookkeeping part - structure referring to the JKP_VAT files used so far.

The new structure of the uniform control file JPK_V7 therefore combines the declaration and VAT records in a single file, thus simplifying the existing procedure and facilitating the reduction of the number of documents processed by the National Revenue Administration, as well as ensuring automatic verification of each VAT settlement with regard to the amounts of tax due and charged.

The JPK_V7 file will contain the following symbols:

• GTU for 13 groups of sensitive goods and services, such as alcoholic beverages and tobacco,
• RO for the fiscal report,
• WEW for an internal taxation document,
• FP for invoice to receipt,
• SW for mail order sales,
• EE for the sale of telecommunication, broadcasting and electronic services,
• TP for sales made to related parties,
• MPP for a split payment transaction,
• TT_WNT for intra-Community acquisitions of goods carried out by a second VAT taxable person in the context of a trilateral transaction under a simplified procedure,
• TT_D for the supply of goods outside the territory of the country by a second in line VAT taxable person under the simplified procedure for a trilateral transaction,
• MR_T for the supply of tourist services taxed on a margin basis,
• MR_UZ for supplies of used goods, works of art, collectors' items and antiques taxed on a margin basis,
• I_42 for intra-Community supplies of goods following their entry under a customs procedure 42,
• I_63 for intra-Community supplies of goods following their entry under a customs procedure 63,
• B_SPV for a single-purpose voucher transfer made by a taxable person acting in his own name,
• B_SPV_DOSTAWA for supplies of goods and services which include a single purpose voucher for the taxable person who issued it,
• B_MPV_PROWIZJA for the provision of intermediary and other services for the transfer of multi-purpose vouchers.

To conclude, the date of the entry into force of the new uniform control file scheme is coming closer and closer. Therefore, it is advisable to prepare well for the arrival of the new obligation, and when sending the declaration, bear in mind the fact that fines for possible mistakes of the taxpayer may amount to as much as PLN 500 for each individual error. An entrepreneur will be able to avoid the imposition of a fine, but he or she will have to correct the errors in the sent file or provide appropriate explanations within 14 days from the date of identifying the incorrectness.