JPK_V7 – new obligations for entrepreneurs
From October 1, 2020, all taxpayers registered as active VAT taxpayers will be obliged to submit a new JPK_VAT (SAF-T). The new structure was to enter into force on July 1, 2020; however, due to the COVID-19 pandemic the deadline has been postponed.
As the Ministry of Finance assures, the changes implemented are primarily intended to simplify the taxpayers’ reporting to the tax authorities. From October, the current VAT-7 and VAT-7K returns will be sent together with the JPK_VAT file in the form of a single electronic document, which will incorporate both the declaration and registration parts.
The new JPK_VAT file will have two variants:
- JPK_V7M – for taxpayers who settle monthly, and
- JPK-V7K – for taxpayers who settle quarterly.
In addition to merging the current JPK_VAT file and the VAT-7/VAT-7K declaration, the new structure has been further amended to include, among others things, the obligation to tag delivery and services with GTU (group of goods and services) symbols. The important issue is that, the obligation applies only to sellers. According to section 10 (3) of the regulation of the Minister of Finance, Investment and Development of October 15, 2019 on the detailed scope of data contained in tax returns and in the register of goods and services tax, the taxpayer is obliged to apply GTU symbols only to domestic and cross-border supplies of goods made by himself. Purchasers of goods and services are not obliged to provide the codes.
According to the GRU symbols, codes from ”01” to ”10” concern selected products, whereas signs from ”11” to ”13” refer to selected services.
| GTU symbol | Group of goods /services |
| GTU_01 | Delivery of alcoholic beverages including: ethyl alcohol, beer, wine, fermented beverages and intermediate products. |
| GTU_02 | Delivery of "sensitive" goods such as petrol, fuel or diesel. |
| GTU_03 | Delivery of heating oil, lubricating oils or other oils of specific CN codes. |
| GTU_04 | Delivery of tobacco products, dried tobacco, electronic cigarette liquid and innovative products. |
| GTU_05 | Delivery of waste as defined in sections 79-91 of Annex 15 to the VAT Act, e.g. wrecks to be scrapped or glass waste. |
| GTU_06 | Delivery of electronic devices and parts and materials for them, e.g. computers or cameras. |
| GTU_07 | Delivery of vehicles and car parts with specific CN codes. |
| GTU_08 | Delivery of precious and non-precious metals, e.g. waste and scrap of non-precious metals, articles of goldsmiths’. |
| GTU_09 | Delivery of medicines and medical devices -medicinal products, foodstuffs for particular nutritional uses and certain medical devices. |
| GTU_10 | Supply of buildings, structures and land. |
| GTU_11 | Provision of services for the transfer of greenhouse gas emission allowances. |
| GTU_12 | Provision of intangible services: consulting, accounting, legal, management, training, marketing, head offices, advertising, market and public opinion research, research and development. |
| GTU_13 | Provision of transport and warehouse management services. |
The obligation introduced by the legislator to tag transactions regarding the specified groups of goods refers only to the JPK file. Therefore, the seller is not obliged to place GTU codes on sales invoices, but may do so in order to facilitate the subsequent generation of a correct JPK file.
In the occurrence of delivery of a particular product or service on a document, the relevant fields corresponding to the symbols GTU_01 - GTU_13 are filled in by the seller by ticking "1". If a particular product or service does not appear on the invoice, the place should remain empty. It should also be mentioned that it is not necessary to split one invoice into several entries, as the file structure provides for the use of multiple GTU symbols for a single document.
At this stage it is difficult to assess whether or not the changes will be more convenient for taxpayers. The new structures, whose aim is, on the one hand, to accelerate the process of analysing and verifying the data included in a tax return, and hence to reduce the time limit for tax refunds, on the other hand impose new requirements on businesses, which may result in additional workload.
Natalia Szymocha, Tax Consultant, ATA Tax Sp. z o.o.
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