Since October 1st, 2020, new regulation will come into effect that require to file a new electronic document, common for submitting VAT declarations and sending information about VAT purchase register.

A new structure of JPK_VAT file must contain additional data (in the recording part):

  • grouping the sales of goods and services (GTU 01-13)
  • marking the transaction type (one of the 13 available)
  • marking the proof of sales

1. Grouping the sales of goods and services

The GTU codes catalogue contains 13 items that relate to so-called goods and sensitive services in which there’s a higher risk of VAT diminishing:

  • GTU_01 Delivery of alcoholic beverages within the meaning of excise tax regulations (not applicable for food services)
  • GTU_02 Delivery of goods that are mentioned in article 103, section 5aa of VAT Act (among other things, fuels and crude oils)
  • GTU_03 Delivery of heating oil
  • GTU_04 Delivery of tobacco products
  • GTU_05 Delivery of waste
  • GTU_06 Delivery of electronic devices
  • GTU_07 Delivery of vehicles and automotive parts
  • GTU_08 Delivery of precious and base metals
  • GTU_09 Delivery of medicine and medicinal products
  • GTU_10 Delivery of buildings, constructions and soils
  • GTU_11 Providing services for greenhouse gas emission allowance trading
  • GTU_12 Providing intangible services such as: counselling, tax, legal, management, trainings, marketing

Selling goods and providing services that weren’t mentioned in GTU catalogue remains without any markings.

2. Marking the transaction type

Sellers and buyers will be obliged to mark goods and services with special attributes regarding the transaction type:

  • SW mail order sales from the country territory
  • EE providing telecommunication, shipping and e-services
  • TP transactions with affiliated entities
  • TT_WNT intra-community acquisition of goods
  • TT_D goods delivery outside the country territory
  • MR_T providing touristic services taxed on a margin basis
  • MR_UZ delivery of used goods, works of art, collectible items and antiquities
  • I_42 intra-community delivery of goods after importing them within customs procedure no 42
  • I_63 intra-community delivery of goods after importing them within customs procedure no 63
  • B_SPV transferring a one-purpose voucher
  • B_SPV_DOSTAWA delivery of goods and providing services subject to a one-purpose voucher to the benefit of the taxpayer that issued the voucher
  • B_ MPV_PROWIZJA providing mediation services and other services subject to a one-purpose voucher of different purposes
  • MPP transactions under an obligation of applying a split payment mechanism

3. Marking the proof of sales

Within new JPK_VAT file, sellers are obliged to provide symbols for proof of sales:

  • RO – a collective, internal document including sales from registers
  • WEW – internal document
  • FP – VAT invoice

What poses a risk of financial fines

If the head of IRS confirms that JPK_VAT file contains errors that make it impossible to verify the transactions made correctly, they will call you to correct them while pointing them out. In such a case you shall send the corrected inventory in 14 days or present explanation. If this isn’t done, the head of IRS has the right to issue a financial fine of PLN 500 for every error.

These fines don’t apply to natural persons that run a business and, for the same deed, are responsible for tax violations and offences based on Penal and Fiscal Code.

1. Tax violation is a type of act prohibited under penalty if the diminishing cost doesn’t go over a minimum wage five times (in 2020, it’s 13,000 PLN). The fine for tax violation varies from PLN 260 to PLN 52,000..

2. Tax offence is a type of act prohibited under penalty in daily rates, restriction of liberty or imprisonment.

  • Failure to submit the JPK_VAT file within the prescribed time limit carries penalty of up to 120 daily rates.
  • Providing unreliable information in JPK_VAT file carries penalty for up to 720 daily rates.

In 2020, daily rate (according to Penal and Fiscal Code) varies from PLN 86.67 to PLN 34,668.

Legal grounds:
– Minister of Finance, Investments and Development ordinance of October 15th, 2019 about a detailed range of data included in tax declarations and in inventory for value-added tax (Poland’s Journal of Laws from 2019) item 1988; latest articles Dz.U. (Poland’s Journal of Laws) from 2020 item 576),
– on March 11th, 2004 on value added tax (e.g. on January 23rd, 2020 – Dz.U. (Poland’s Journal of Laws) from 2020, item 106, latest articles: Dz.U. (Poland’s Journal of Laws) from 2020, item 1106).



See also