Tax Alert – White List of taxpayers

On 1 September 2019 a „white list of VAT taxpayers” was launched. It may force non-Polish companies to open a Polish bank account.
The main goal of the white list is to enable Polish VAT taxpayers to verify their business partners. The white list contains, among others, numbers of bank accounts of entities which are registered for VAT purposes in Poland. Currently, non-Polish bank accounts are not included on the white list and it is very likely that they will not be shown on the list in the future.

From 1 January 2020 sanctions for making bank transfers to bank accounts which are not on the white list will come into force. In case of transactions of PLN 15,000 (or higher) the payment, as a rule, should be made to the account included on the white list. If the payment is made to the bank account which is not on the list, a taxpayer will be deprived of the right to qualify the expense as a tax cost in the part exceeding PLN 15,000. Additionally, in such case a buyer will be jointly and severally liable for the supplier’s VAT arrears - in the part attributable to the given transaction. Sanctions can be avoided if, within three days of sending an incorrect transfer, a taxpayer notifies the head of the tax office competent for the seller about the transfer. Sanctions won’t be applicable either if the bank transfer is made in the split payment mechanism.

As a result of the above changes, one may expect that Polish purchasers of goods and services will refuse making bank transfers to non-Polish bank accounts of entities registered for VAT purposes in Poland. Foreign bank accounts will not be included on the white list and therefore a bank transfer to such account will trigger tax risks for Polish companies.

Taking the above into account, foreign entities registered for VAT purposes in Poland should consider opening a bank account in a Polish bank.

Please, be informed that we can assist in the process of opening a Polish bank account.

In case of any questions, please contact us.

[email protected]

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Adam Sękowski
Adam  Sękowski
Tax Manager