The Ministry of Finance has submitted for consultation a draft amendment to the regulation regarding the detailed scope of data contained in tax returns and VAT records. The proposed changes relate to JPK_VAT and the introduction of mandatory e-invoicing within the National e-Invoice System (KSeF), scheduled for mid-2024.
The solutions in the project are aimed at adapting JPK_VAT with the declaration to the mandatory KSeF, therefore they will enter into force in parallel with the statutory solutions – i.e. from July 1, 2024.
Main assumptions of the project:
- adapting the regulation to changes in VAT refund deadlines (including shortening the basic refund deadline from 60 to 40 days, removing the additional 40-day refund deadline),
- introduction to JPK_VAT with declaration of the invoice identification number in the National e-Invoice System,
- marking invoices issued during the period of failure of the National e-Invoice System and during the period of unavailability of this system, also in the case when issuing an invoice in KSeF was not possible for reasons attributable to the taxpayer.
The functionalities introduced by the Ministry of Finance in JPK_VAT with the declaration will enable automatic verification of consistency between the declared and paid VAT and will increase the accuracy of verification of VAT refund applications submitted by taxpayers.
KSeF – obligatory from July 2024
It is worth recalling that from July 2024, issuing e-invoices in KSeF will become mandatory for active VAT taxpayers. However, taxpayers who are exempt from VAT subjectively (due to the volume of sales up to 200 000 PLN) or objectively (due to the type of activities performed) will have to issue electronic invoices from 1 January 2025. According to the published draft, taxpayers will be obliged to use KSeF they had to provide in the uniform control files the identification number of the invoice issued in this system, as well as the following designations:
- “OFF” when the invoice is issued during a KSeF failure or when, for reasons attributable to the taxpayer, it is not possible to issue a structured invoice,
- “BFK” when the invoice will be issued electronically or on paper without using KSeF (i.e. in cases where there will be no obligation to issue an invoice using KSeF).
In principle, the regulation will enter into force on 1 July 2024.
