Poland – Pre-filled JPK – VAT

The Ministry of Finance in Poland is currently working on a draft amendment to the VAT Act that would enable the Tax Authority to create a pre-filled JPK_VAT file together with the associated VAT declaration using information already collected by the Tax Authority through invoicing, reporting and fiscal systems. Once implemented, the taxpayer would still be responsible for ensuring the correctness of declarations pre-filled and if necessary, make required corrections prior to the submission of declarations to the Tax Authority.

As per the proposal, this solution is to be introduced in phases with the starting date in quarter 4 2029.

The introduction of a pre-filled JPK_VAT file together with the associated VAT declaration may sound like a reduction in administrative burden for businesses, however the Ministry of Finance warns that the liability does not shifts and taxpayer will still be responsible for making sure the declaration is submitted and its correctness. For example:

–  A pre-filled draft of JPK_VAT file and the associated VAT declaration will not get automatically filed if taxpayer ignores a draft declaration and deadline date passes.
–  A role of accountants and tax teams is still crucial in the process. While the information held by the Tax Authority may indicate that particular invoice was issued / received, it may not necessarily apply the correct VAT treatment when it comes to partial-exemption calculation, bad debt relief, deductibility rules etc.

The pre-filled declaration may therefore be used by businesses to cross check values against their internal ERP systems, however it shouldn’t replace taxpayers own VAT books and internal controls.