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Poland and e-invoicing clearance model October 2021



Poland last week issued a public consultation on imposing mandatory electronic B2B invoicing by 2023 to help reduce VAT fraud. Initially, there will be a voluntary phase from January 2022. The incentive for taxpayers to opt voluntarily is a quick VAT credit repayments of 40 days and no requirement anymore to submit SAF-T (JPK_FA) files. The consultation lasted until 23 February 2021.

The Ministry of Finance published the components in February. In August, the e-invoice format characters were announced.

The new proposed electronic tax and invoicing system are very similar to the Italian one. Taxpayers VAT registered in Poland must submit all invoices to a central platform called the National Electronic Invoicing System –KseF, identical to the Italian Portal. This will include live submission of e-invoices to the National System of e-invoices for authorization (KSeF, Krajowy System e-Faktur). Under the proposed system, taxpayers will prepare invoices in their ERP systems and send them via an API to the KSeF. In the KSeF, each invoice will be timestamped and assigned a number. Invoices can be downloaded from the Portal in the original format or PDF. The Portal will archive electronic tax documents for ten years.

As an incentive to use that new platform, the government has announced a 1/3 reduction in VAT return times (in 20 days) for its users and has exempted its users from declaring JPK_FA files.

A phased roll out

  • October 2021: Beginning of test period. Companies that would like to volunteer to participate in system testing can do so.
  • January 2022: Voluntary phase. Companies that would like to can begin electronically invoicing.
  • January 2023: mandatory use of the electronic invoice.

During the voluntary phase, the structured invoices will coexist with paper invoices and any other electronic invoices in the Polish market.

The new proposed electronic tax and invoicing system are very similar to the Italian one. Taxpayers VAT registered in Poland must submit all invoices to a central platform called the National Electronic Invoicing System –KseF, identical to the Italian Portal. As an incentive to use that new platform, the government has announced a 1/3 reduction in VAT return times (in 20 days) for its users and has exempted its users from declaring JPK_FA files.