Dear Sir or Madam,
from July 1, 2020, every entity registered as an active VAT payer will be required to submit a new JPK_VAT declaration. This obligation applies to large, medium, small, and micro-entrepreneurs.

The new JPK_VAT file is a single electronic document that will replace the existing VAT-7 and VAT-7K declarations and will include both the VAT declaration and VAT records. It will consist of two parts: a declaration section and an information section.

New JPK_VAT 2020 Structure

In addition to the data submitted in the current VAT-7 and VAT-7K declarations, the new JPK_VAT will contain additional data needed to analyze the accuracy of VAT settlements and to audit taxpayers. In turn, items from the current VAT-7 or VAT-7K declarations will be transferred to part of the new JPK_VAT file. This eliminates the obligation for taxpayers to submit VAT returns and selected other information separately.

New JPK-VAT only for VAT-7 and VAT-7K

It should be noted that the changes to JPK_VAT will only apply to VAT settlements, which are submitted in the form of VAT-7 and VAT-7K declarations. The new JPK-VAT will not apply to the abridged value added tax return for passenger taxi services taxed on a lump sum basis (VAT-12), or to other tax returns or information, to which the existing regulations will apply (VAT-8, VAT-9M, VAT-10, VAT-11, VAT-13, VAT-21, VAT-23, VAT-26, VAT-UE, VAT-UEK, VAT-R, VAT-Z, VIN-R and VIU-R, as well as VIN-D and VIU-D).

New designations for groups of goods and services

An additional change to be introduced in the JPK_VAT file is the requirement to designate specific groups of goods and services (GTUs). This applies in particular to the sale of alcohol, cigarettes, fuels, electronics, vehicles and car parts, and real estate. Furthermore, specific types of transactions, such as triangular transactions, electronic services, transactions with related entities, and transactions covered by the split payment mechanism, must also be designated.

Deadlines for submitting JPK_VAT

The deadlines for submitting JPK_VAT will not change, i.e., the deadline for submitting the return will remain the 25th day of the month following the end of the given settlement period (monthly or quarterly). However, it should be noted that taxpayers who settle quarterly are required to submit VAT records for the first and second months of the given quarter to the appropriate tax office by the 25th day of the month following the month to which the records relate.

According to the legislator's original assumption, the new JPK_VAT was to apply to large entrepreneurs from April 1, 2020. However, under the so-called anti-crisis shield, this deadline was postponed to July 1, 2020 for all entrepreneurs registered as active VAT payers.

Realizing that taxpayers may encounter many issues and doubts in connection with the implementation of the new regulations, we are ready to support you in preparing the new JPK, verifying the adopted assumptions and procedures, and assigning groups of goods and services to the appropriate codes.


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