Responsibilities related to the white list
The VAT whitelist forces all taxpayers to check their contractors every time they make a transfer of PLN 15,000 or more. So, if we have to send a transfer with an amount that falls within this range, we must first verify that the company or person is on the electronic list of VAT taxpayers, and then compare its bank account number with the one on the white list.
Important
Checks should always be made on the day of the transfer – it is the date of the order that is binding in case of a possible inspection. If it turns out that the account indicated differs from the account number appearing on the VAT white list, and the businessman explains that only a few days earlier everything matched, such argumentation will not be understood, and the businessman will face the risk of possible sanctions.
What information will we find on the white list?
Wanting to make sure that our counterparty is an active VAT taxpayer, we can check it: to do so, we need to visit the official list of VAT taxpayers – we just need to have its account number, TIN, REGON, or simply enter the name of the entity.
The search results will include such information as:
- company name;
- TAX ID;
- taxpayer status;
- REGON;
- address;
- bank account number;
- date of registration as an active VAT payer
and, in a situation where the taxpayer is no longer an active VAT taxpayer:
- date of deletion of registration as a VAT taxpayer;
- legal basis for deletion.
This, of course, is not all the information, but it is the most relevant for the purpose of making deals and verifying contractors.
Verification of multiple contractors
Such a check of the company in the list of VAT taxpayers is not time-consuming, but things are different when you do business with dozens and sometimes even a few hundred contractors.
In such a situation, instead of checking each taxpayer manually, you can use an online application developed by PragmaGO.tech. Listapodatnikow.pl will allow you to import a list of contractors and check them with one click both on the white list of VAT taxpayers and in CEIDG and VIES database.
What else can you do with the listapodatnikow.pl application?
- Enter the .XLS file containing your contractors’ bank account numbers and you will check all the numbers at once;
- Verify the presence and details of multiple contractors on the white list of VAT taxpayers;
- Make sure the transfer package has the correct data before you send the order to the bank;
- Extend the functionality of the business.gov.pl API with a dedicated REST API!
Factoring vs. VAT white list
As expected, the white list of taxpayers is also having a major impact on factoring, particularly some variations of the service.
Taxpayer whitelisting vs. open factoring
For those entrepreneurs who regularly use open factoring, I hasten to reassure you: the taxpayer white list has not affected this type of factoring, except that, of course, entrepreneurs should check the account number to which they deposit money.
This means that the factoring company must verify the factor before it sends the money to him, while the recipient (the counterparty whose invoice is the subject of the factoring service) must also verify that the account number received matches the entry on the whitelist before sending the money to the new bank account (i.e., the factor’s account).
VAT white list vs. silent factoring
In this case, the changes have gone much further, because the essence of silent factoring is the ability to carry out transactions without the recipient’s knowledge, and the white list of taxpayers de facto prevents this from playing out in the standard way. Why?
In silent factoring (also known as undisclosed factoring), a company that has an invoice (or invoices) to pay is unaware that the invoice has already been financed by the factoring company – it pays the money to the bank account number indicated by the creditor and… as of September 2019, it must check it against the white list of VAT taxpayers. Thus, if a factoring service has been launched against this invoice, the creditor’s data will not appear in the list, but the factoring company’s.
So since it is not possible to assign an invoice so as to carry out standard undisclosed factoring, and the white list of taxpayers is VAT is the right reason for this, does silent factoring still work at all?
Yes, although on a different basis.
How does silent factoring currently work?
Today, factoring companies offer silent factoring, in which the factor submits invoices for financing, the factor pays the amount as agreed, and the recipient pays the amount due not to the factor’s account, but to the account of his creditor. Thus, from the contractor’s perspective, nothing changes.
So what is the difference? In the arrangements between the factoring company and the factor, according to which the factor agrees to pay the liability to the factor’s account number immediately after receiving payment from its counterparty.
Again, the factoring company can protect itself in case of delays on the part of the counterparty, or use the assistance of the factoring company, for example, in the context of debt collection.
