Poland has established an online database of VAT-registered businesses, known as the Polish VAT Whitelist (“Biała Lista” in Polish). This list comprises essential information regarding VAT payers, including their bank account numbers.
In addition to the monthly SAF-T VAT filing, companies in Poland are required to submit a SAF-T file "on request," which includes various legal requirements. This obligation arises in situations such as preliminary tax inquiries, tax audits, and tax proceedings, where the SAF-T file must be presented to the Polish tax authorities promptly. To prevent disputes or penalties, it is crucial for companies to be adequately prepared.
Payments exceeding PLN 15,000 made to suppliers not listed in the Whitelist will disallow buyers from deducting those expenses for income tax purposes. Additionally, payments directed to accounts not included in the Whitelist can result in joint liability for VAT obligations - up to the VAT amount of the related transaction - on the part of the supplier. These regulations have been in effect since January 1, 2020.
The Whitelist contains the following key information:
- Entities that are not registered for VAT purposes or that have been deregistered.
- Entities registered as VAT taxpayers (including active and exempt VAT taxpayers), as well as those whose VAT taxpayer registration has been reinstated.
- Bank account numbers corresponding to the tax identification or update notifications.
- The list is maintained and updated on a daily basis.
Implications for Businesses
Taxpayers should incorporate cross-checking the Whitelist as a mandatory internal control within their payment and settlement processes. From a tax compliance perspective, the following measures should be taken to minimize tax risks:
- Before executing a payment (i.e., on the day of the transfer order), verify that the payment is directed to a bank account included in the Whitelist.
- After payments have been executed, confirm that they were made to bank accounts listed in the Whitelist.
- Notify the head of the respective tax office of any potential errors within three days of the transfer order date to avoid sanctions.
KGT SAP add-on
For companies utilizing SAP, KGT has developed an SAP add-on that automates the relevant data checks. This add-on extracts all pertinent information from SAP and performs batch validations against the Whitelist. The results are presented in a cockpit that highlights any discrepancies or validation errors.
Additionally, results are archived within SAP, enabling taxpayers to demonstrate during future tax audits that they have implemented state-of-the-art tax controls. From a tax risk management perspective, it is also possible to review transactions that have already occurred.
Key Features
- Automated Validation: Batch-check payments against the Polish VAT Whitelist directly from SAP.
- Cockpit Overview: Displays validation results and highlights discrepancies for immediate action.
- Historical Archiving: Stores validation results within SAP for audit readiness and regulatory reporting.
- Real-Time Compliance: Ensures payments align with Whitelist requirements before execution.
- Seamless SAP Integration: Works within existing SAP ECC or S/4HANA environments without additional interfaces.
Benefits
- Reduce Tax Risk: Prevent disallowed deductions and joint liability for VAT by ensuring payments comply with Whitelist regulations.
- Compliance Assurance: Meet Polish legal requirements consistently, including SAF-T reporting on request.
- Operational Efficiency: Automate checks, eliminating manual cross-referencing and minimizing errors.
- Audit Readiness: Provide evidence of robust tax controls during tax audits.
- Process Transparency: Easily monitor and review both pending and completed payments for compliance.
The Polish VAT Whitelist is an online database of VAT-registered businesses, including their bank account numbers. It helps ensure that payments are made to legitimate VAT-registered suppliers.
Payments over PLN 15,000 to suppliers not on the Whitelist can prevent income tax deductions and create joint VAT liability for the payment amount, making compliance essential.
Entities registered or deregistered for VAT, active and exempt VAT taxpayers, bank account numbers linked to VAT registration, and daily updates on registration status and changes.
Before payment: Verify the supplier’s account is on the Whitelist.
After payment: Confirm the payment went to a Whitelist account.
Error reporting: Notify the relevant tax office within three days of any issues.
The add-on automates Whitelist checks, extracts relevant data from SAP, performs batch validations, and highlights discrepancies or validation errors in a cockpit.
Yes. The add-on archives results in SAP, allowing companies to review past payments and demonstrate compliance during tax audits.
By automating Whitelist checks and maintaining audit-ready records, it minimizes penalties, ensures income tax deductibility, and reduces the risk of joint VAT liability.