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VAT returns will disappear and be replaced by the Standard Audit File.
The year 2020 began with VAT changes. The Standard Audit File has been a way of reporting data to the tax authorities since 2016. It has become such a widespread tool for officials and such an effective form of control that the Ministry of Finance decided to replace VAT returns with a new JPK_VAT file. The relevant regulation has already been published in the Journal of Laws. According to lawmakers’ estimates, the VAT changes will affect more than 1.7 million taxpayers.
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What is the Standard Audit File?
The Standard Audit File is a set of data that companies must provide to the tax authorities in a specified structure. JPK files are sent in XML format, requiring companies to implement electronic accounting. Currently all companies must report data in JPK files. On request, the tax authorities receive data on tax books, inventory, invoices, the tax revenue and expense ledger and revenue records. The JPK_VAT file, reflecting companies’ transactions, must be sent every month. This tool has become so widespread and, in the tax authority’s view, so effective that a modernised JPK_VAT will replace VAT returns.
New JPK_VAT. From when?
The new JPK file will replace two returns: VAT-7 and VAT-7K. These forms have so far been filed by all active VAT taxpayers. Monthly VAT taxpayers file VAT-7, while quarterly taxpayers file VAT-7K.
The largest companies currently required to file these returns will have different obligations from 1 April 2020. They will submit the new JPK_VAT, which will also contain data from the returns in use today. From 1 July 2020, other taxpayers – small, medium-sized and micro businesses – will also submit the new JPK_VAT.
What data will be in the new JPK file?
The new structure will comprise two parts: the return and the register. According to the Ministry of Finance, combining JPK_VAT and the return should simplify tax settlements and reduce VAT taxpayers’ reporting burden. JPK_VAT will contain:
- a set of information on purchases and sales derived from VAT records for the period,
- items from the existing VAT-7 (VAT-7K) return,
- additional data needed to analyse whether the settlement is correct.
The file structure provides for additional information not previously included in the VAT return. This includes:
- goods-group codes (13 groups),
- additional fields on the type of transaction,
- information on transactions with related parties.
According to the Ministry of Finance, entrepreneurs obliged to send JPK_VAT will send just one file containing all required information. JPK_VAT will be submitted only electronically each month, by the 25th day of the following month as before. The new JPK_VAT file will have two variants, similarly to the existing VAT-7 return: JPK_V7M for taxpayers settling monthly and JPK_V7K for those settling quarterly.
New JPK_VAT. Rules for sending the file
Quarterly taxpayers will settle under different rules from those who submit JPK_V7M every month. Quarterly taxpayers will send a JPK_V7M file but complete only the register part for the first two months of each quarter. After the quarter ends, they will complete the register part for the third month and the JPK_VAT return part for the entire quarter.
Example of monthly settlement
JPK_VAT for January – the entrepreneur sends it by 25 February
JPK_VAT for February – the entrepreneur sends it by 25 March
JPK_VAT for March – the entrepreneur sends it by 25 April
Example of quarterly settlement
JPK_VAT register part only for January – the entrepreneur sends it by 25 February
JPK_VAT register part only for February – the entrepreneur sends it by 25 March
JPK_VAT register part for March and return part for January, February and March – the entrepreneur sends it by 25 April
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