What was it like before?
Entrepreneurs who are also active VAT taxpayers until September 30, 2020 were required to submit VAT-7 returns and a VAT JPK file (on a monthly or quarterly basis, depending on the option chosen).
Both files contained some of the same data, with the VAT JPK file requiring more data to be submitted to tax authorities than the vat return. As a result, a new Single Control File – code-named JPK_V7 – has been decided upon.
JPK_V7 – when does it come into effect?
Initially, the plan was to introduce the new control file first for large companies – this was to happen on April 1, 2020. However, due to the pandemic situation, it was decided to launch the changes six months later simultaneously for all business sectors.
The obligation to file JPK_V7 has been in place since October 1, 2020.
JPK_V7 – who does it apply to?
As you read this article, the new rules are already in place. However, they do not apply to all companies.
The obligation to submit the JPK_V7 file on a regular basis applies to sole proprietors and companies that are active VAT taxpayers filing a VAT-7 return so far.
Important!
Even if the taxpayer provides services under Art. 43 of the VAT Law, i.e. exempt from VAT, and so it is necessary to submit the JPK_V7 control file.
What does the JPK_V7 file contain?
The new Single Control File is divided into two logical structures: record and declaration. The record part corresponds to the former JPK_VAT file, while the declaration part is an updated version of the VAT return.
Three additional types of information have been added to the data that the previously valid control files contained: GTU codes, transaction procedure codes and document type codes.
Group of goods and services (GTU) codes.
The first of the new mandatory markings are the codes with which businesses must label the goods or services they sell. This obligation does not apply to buyers.
Important!
GTU codes do not apply to all types of goods sold and services rendered, but only to those deemed by the Ministry of Finance to be vulnerable to tax fraud.
Currently, the code list contains thirteen items – ten for goods and three for services:
| GTU CODE | DETAILED DESCRIPTION |
| GTU_01 | Alcoholic beverages – ethyl alcohol, beer, wine, fermented beverages and intermediate products as defined by the excise tax regulations |
| GTU_02 | Up to PLN 1,000 with the minimum value of share capital (PLN 5,000) |
| GTU_03 | From about PLN 1,000 to 1,500 |
| GTU_04 | From PLN 1,500 to PLN 5,000, depending on the number of people employed in the transformed enterprise |
| GTU_05 | The waste specified in item. 79-91 appendix. No. 15 to the VAT Act |
| GTU_06 | Electronic devices, parts and materials for electronic devices as defined in item. 7-9, 59-63, 65, 66, 69, and 94-96 appendix. No. 15 to the VAT Act |
| GTU_07 | Vehicles and automotive parts as defined by CN codes 8701-8708 and CN 8708 10 |
| GTU_08 | Precious and base metals as defined in item. 1-3 appendix. No. 12 to the VAT law and in item. 12-25, 33-40, 45-46, 56, and 78 attached. No. 15 to the aforementioned. laws |
| GTU_09 | Drugs, medical devices, medicinal products, foodstuffs for special nutritional purposes and medical devices covered by the notification requirement referred to in Art. 37av para. 1 of the Pharmaceutical Law |
| GTU_10 | Real estate – buildings, structures and land |
| GTU_11 | Services for the transfer of greenhouse gas emission allowances referred to in the Law on the Greenhouse Gas Emission Trading System |
| GTU_12 | Intangible services – consulting, accounting, legal, management, training, marketing, advertising, central company services, and market research and opinion polls for scientific research and development work |
| GTU_13 | Transportation and warehouse management services |
Important!
Information about GTU codes should be included in the JPK_V7 file – there is no need to include them on invoices.
Transaction procedure codes
Some transactions are subject to special VAT accounting procedures. It is for this type of transaction that additional designations are provided:
| PROCEDURE CODE | WHAT DOES IT MEAN? |
| SW | Mail order |
| EE | Telecommunications, broadcasting and electronic services |
| TP | Transactions by related parties (Art. 32(2)(1) of the VAT Act) |
| TT_WNT | Intra-Community acquisitions of goods in triangular transactions (Section XII, Chapter 8 of the VAT Act) |
| TT_D | Supplies of goods outside the national territory in triangular transactions |
| MR_T | Travel services taxed in accordance with Art. 119 of the VAT Act |
| MR_UZ | Second-hand goods, works of art, collector’s items and antiques taxed under Art. 120 of the VAT Act |
| I_42 | Intra-Community supply of goods after importation under customs procedure 42 |
| I_63 | Intra-Community supply of goods after importation under customs procedure 63 |
| B_SPV | Transfer of a single-purpose voucher made by a taxpayer acting in his own name |
| B_SPV_DELIVERY | Supply of goods and services to which the single-purpose voucher relates to the taxpayer who issued the voucher |
| B_MPV_PROVISION | Brokerage and other services for. transfer of a miscellaneous voucher |
| MPP | Split payment |
| IMP | Import of goods |
Document type codes
The last of the new mandatory designations are codes with which businesses are required to describe certain types of documents:
| SALES RECEIPTS | PROOF OF PURCHASE |
| RO – cash reports | VAT RR -Invoices for the purchase of agricultural products from a flat-rate farmer |
| WEW – Internal documents for activities not documented by purchase/sales documents | WEW – Internal documents for activities not documented by purchase/sales documents |
| FP – Invoices to receipts | MK – Expense invoices from cash accounting businesses |
| PurchaseVAT_Marza – Sales taxed at the margin in accordance with Art. 120 of the Act |
Types of JPK_V7
JPK_V7M
We send the JPK_V7M control file monthly by the 25th of the month following the accounting month. The file to be submitted must contain two parts: record and declaration.
JPK_V7K
The JPK_V7K control file is also sent monthly by the 25th day of the month after the month to which the settlement applies. The difference between the two versions of the document is in the third aspect – the JPK_V7K file should contain only the record part in the first and second months of the accounting quarter. It is only in the last month of the accounting quarter that it must consist of a record and declaration part. The declaration part should then contain data covering the entire quarter.
Administrative penalties for errors in JPK_V7
If errors are found in the JPK_V7 file sent to the relevant tax authority, which will prevent the transaction from being audited, entrepreneurs face an administrative penalty of PLN 500. What’s more, each mistake in JPK_V7 will cost our business 500 zlotys. Of course, only if we do not correct the error and send a correction to the submitted control file.
The tax authority in charge of verifying the accuracy of the transactions carried out by our company will first send the relevant information. We then have 14 days to respond. Explanations will need to be provided at this time. If it turns out that the error was the result of a mistake, the authority will not impose a penalty.
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