From October 1, 2020, the provisions specifying the obligation to send both VAT returns and VAT records in a new JPK_VAT file sent to the tax authorities enter into force. The changes will immediately apply to all categories of entrepreneurs, regardless of their size (micro, small, medium, large enterprises) – who are registered as active VAT payers. Originally, large companies were to use the new JPK_VAT from April 1, and other taxpayers from July 1, 2020. However, the effective dates of the regulations were postponed due to the coronavirus pandemic.

The new JPK_VAT will be available in two variants:

  • JPK_V7M – will be intended for taxpayers who pay monthly. You will need to complete it in both parts and send it by the 25th of each month for the previous month;
  • JPK_V7K – for taxpayers who pay quarterly.

The first JPK_V7M in the new variant will therefore be sent by November 25 for the previous month.

The Regulation of the Minister of Finance, Investment and Development of October 15, 2019 on the detailed scope of data contained in tax declarations and records in the field of tax on goods and services (Journal of Laws of 2019, item 1988) specifies the scope of data to be contain a new JPK_VAT file – many of them have not been identified in JPK_VAT files so far.

Pursuant to § 10 para. 3 of above regulation, data identified in JPK_VAT will include mandatory designations concerning, among others:

  • deliveries of alcoholic beverages – designation “01”;
  • deliveries of goods subject to excise duty – designation “02”;
  • deliveries of heating oil within the meaning of the provisions on excise duty and lubricating oils, excluding plastic lubricants covered by this item – designation “03”;
  • providing intangible services – exclusively: advisory, accounting, legal, management, training, marketing, head offices, advertising, market research and public opinion research, in the field of research and development rights – designation “12”;
  • provision of transport and warehouse management services – designation “13”.

Moreover, § 10 para. 4 above of the regulation specifies further additional data that will be included in the new JPK_VAT file. In particular, mandatory designations will concern transactions:

  • subject to the obligation of the split payment mechanism – the indication “MPP”,
  • with existing relations between the buyer and the supplier of goods or service provider – the designation “TP”.