Einhaltung der Weißen Liste in Polen: Was jedes mehrwertsteuerlich registrierte Unternehmen wissen muss.
The Polish VAT White List (Biała Lista Podatników VAT) is an official electronic register maintained by the Head of the National Revenue Administration (KAS), enabling taxpayers to confirm the VAT status and bank account details of their suppliers.
The register includes essential data such as the VAT number, business name, VAT registration or de-registration status, and the bank accounts officially reported to the tax authorities.
Its primary purpose is to strengthen the tax system, reduce VAT fraud, and ensure the safety of commercial transactions. The White List has become a key compliance requirement for Polish VAT payers, particularly with respect to payments above statutory thresholds.
Obligations for VAT‑Registered businesses in Poland:
- Payments Above PLN 15,000/ around EUR 3,500 (Gross)
When a VAT‑registered business in Poland pays a supplier more than PLN 15,000, the payment must be made to the supplier’s bank account listed on the White List, which applies regardless of whether the invoice is denominated in PLN or foreign currency.
Failure to comply, can lead to significant consequences for the customer if they pay an amount exceeding PLN 15,000 to an account outside the White List (e.g a supplier’s euro account). The customer may become jointly and severally liable for any unpaid VAT associated with that transaction.
Where can businesses verify their Polish suppliers bank account?
Businesses can verify a supplier’s bank account directly on the Polish government’s official White List search engine available on the Polish Ministry of Finance website.
As the White List is updated daily, it is recommended that businesses review their Polish suppliers’ details each day before making payments to ensure:
- any changes in bank account status are promptly captured,
- the supplier’s VAT registration status remains current, and
- payments above PLN 15,000 (Gross) are always made to a compliant account.
Businesses that regularly monitor the White List, significantly reduces their risk of penalties, loss of tax deductibility, and exposure to joint VAT liability.
Correcting an Incorrect Payment
Where a Business inadvertently pays into a non‑listed account, commonly a foreign‑currency account such as EUR, they may avoid the above sanctions by filing a ZAW‑NR notification with the supplier’s competent Polish tax office within 7 days of making the payment.
This form shields the customer from both the denial of VAT deductibility and joint liability provisions.
- Payments Below PLN 15,000/ around EUR 3,500 (Gross)
Where the payment does not exceed PLN 15,000 (Gross), the compliance requirements are less strict:
No obligation for businesses to use the suppliers bank account listed on the White‑List:
The business may pay the supplier’s euro account or Polish account at their discretion.
No tax sanctions:
The limitations on deducting expenses and the joint‑liability rules do not apply for payments under the PLN 15,000 (Gross) threshold.
Should businesses still use the White List account?
Where a business makes a payment to a Polish supplier for less than PLN 15,000, they are not legally required to pay the White List bank account. However, it is practically advisable to always use the account shown on the White List. Doing so ensures consistency, reduces the risk of administrative burdens and avoids the possibility of unintentionally breaching rules once a payment exceeds the PLN 15,000 threshold.
Payments excluding VAT
In Poland, if a domestic supplier is listed on the White List and the amount owed by its customer does not include VAT, the customer is not required to pay the PLN 15,000 amount to the supplier’s White List‑registered bank account.
The obligation is only applicable in respect of invoices which are subject to Polish VAT.
Schlussfolgerung
The VAT White List remains a critical compliance tool for all companies conducting business in Poland. Strict adherence to the payment requirements particularly for amounts exceeding PLN 15,000 (Gross) is essential to avoid loss of VAT deduction and exposure to joint VAT liability.
Businesses should implement robust internal controls to verify suppliers’ bank accounts before making payments and be prepared to submit a ZAW‑NR form when necessary.
Kontakt
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