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Era of VAT returns comes to an end

JPK_VDEK is a working title of the new structure of the standard audit file which the Ministry of Finance is currently working on. The new file is supposed to completely replace the current JPK_VAT file and is going to include a wider range of information about the monthly activity of the VAT taxpayer. The idea of the legislator is to eliminate the VAT return forms from our month-to-month tax routine. It is also another form of combating the VAT frauds and a way to simplify the Polish tax system.

The obligation to provide a set of data regarding purchases and sales made by the active VAT taxpayer in a form of a logical structure was initially imposed only on the biggest entities back in July 2016. Currently, the JPK file is also submitted by small and micro enterprises. It is estimated that over 1.5 m companies submit almost 1.7 m files every month, and the changes are perceived very positively (faster verification of settlements in turn increases the effectiveness of tax controls).

However, the introduction of the described simplifications resulted in a situation where the taxpayer is obliged to provide the tax office with the data later duplicated in the VAT return form, which, for many, seems an unnecessary procedure generating additional costs.

The idea of the Ministry is simple – all reporting methods known so far are to be replaced by one file.

The JPK_VAT file in the present shape is not sufficient to provide the tax authorities with the information about the requested amount or the deadline of the VAT refund (including the amount to be carried forward to the next period). Thinking about the new JPK_VDEK it seems obvious, that not only the name will be subject to change, but the amendment will, above all, increase the functionality of the structure by extending and broadening the range of data reported to the tax authorities. In consequence, it will lead to unification of the reporting periods. For the taxpayers, it translates to saving both the time spent on preparing the settlement and the costs incurred on the analysis of the data – as all information will be included in a single xml file.

When will the change affect us in practice? For the time being, the Ministry limits itself to an indication that it will be in 2019. As of the present moment, the exact and final date of introducing the new solutions, which will also require adjustments in the current legal framework, remains unknown. Additionally, implementing regulation is going to be formulated, which would describe the so-called scheme (a standard used to define the structure of the xml file), according to which the files will be prepared and verified.

We are all waiting impatiently for the official information in this respect, as at this stage, taking into account the main idea of the legislator, the scheduled changes should be evaluated favourably. The only concern seems to be a close deadline of implementing JPK_VDEK, as some sources set it out in February 2019 (for the January 2019 settlement). Adjusting the companies’ IT systems to the new legal framework is  time-consuming, as shown in the recent years with the implementation of JPK files for the first time. We hope that both the accounting companies as well as millions of enterprises will be given a safe time-margin to align to the new practices/regulations. It seems that the coming days are the last possible date for the publication of details of the new file.

Beata Burdzińska

VAT Consultant

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