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The split payment mechanism must be obligatorily applied for transactions:

  • concluded by and between taxpayers (B2B) and subject to VAT in Poland,

  • for which the invoice value exceeds PLN 15,000,

  • of specified goods and services.

Implementation of the split payment mechanism requires both sellers (who need to include the information on the use of the split payment mechanisms on the invoices they issue) and the purchasers (who are required to make the payment through a dedicated transfer message) to adjust their internal accounting and payment systems accordingly.

Failure to meet the obligations related to the split payment mechanism may lead to imposition of tax sanctions on both the seller and the purchaser. Furthermore, it is associated with the risk of incurring penal fiscal liability for persons responsible for tax settlements (e.g. the Management Board, financial directors, chief accountants).

Practice so far shows that the current VAT regulations often fail to sufficiently clarify many practical doubts related to split payment mechanism application (such as settlements of correcting invoices). This is why keeping track of the latest developments in regulatory practices of tax authorities, including tax rulings issued, becomes of utmost importance.

How we can help

Identification of transactions to which the split payment mechanism should be obligatorily applied

Our dedicated team of experts will conduct a comprehensive review of your company's sales and purchase transactions in order to identify those to which the split payment mechanism should be obligatorily applied. Should there arise any doubts as to the correct assignment of PKWiU/CN codes to given goods or services, we may assist you in drafting an application for the issuance of a Binding Rate Information.

Assistance in the implementation of the split payment mechanism

Our dedicated team of experts will help you implement procedures related to proper identification and marking of invoices to which the split payment mechanism should apply. Identification of sales and purchase invoices covered by the obligatory split payment regime is also of key importance in the context of reporting under JPK_V7M / JPK_V7K, applicable as of 1 October 2020.

We may also provide your organization with comprehensive support in implementation of the mandatory procedures for making and accepting transfers in the split payment system. Should there arise any doubts as to the correctness of VAT-related procedures applied at your organization, we may assist you in preparing an application for issuing an individual tax ruling, to mitigate the risk of tax and penalty exposures due to non-compliance with the split payment regime.

See also