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Daily bank statements in SAF-T format

The Ministry of Finance intends to impose an obligation to file daily SAF-T reports on taxpayers

Tax Alert 4/2017 | 24 May 2017

Starting from 1 September 2017 banks will be obliged to file daily bank statements of businesses in the SAF-T format. The new requirement does not apply to microenterprises and public finance entities. Taxpayers holding accounts with foreign banks are obliged to file daily reports independently.

The government draft amendment to the Tax Code introduces an obligation to provide the Head of the National Tax Administration with daily bank statements in the SAF-T format.

The requirement will apply to legal persons, organizational units without legal personality and sole proprietors within the meaning of the Act on freedom of economic activity, excluding microenterprises and entities from the public finance sector.

For taxpayers holding a bank account with a bank or a bank branch registered in the Republic of Poland or a credit union, SAF-T will be submitted directly by a bank or a credit union based on a written authorization of a taxpayer. Taxpayers holding a bank account with a foreign bank will have to file daily reports in the SAF-T format independently.

According to the amendment, bank statements will be provided for 24-hour periods until the end of the following 24-hour period excluding Saturdays and public holidays. The bank statements will be provided by banks and credit units through the IT system of the Polish clearing chamber (KIR S.A.). Taxpayers preparing SAF-T reports independently will send them to the dedicated gateway of the Ministry of Finance.

The new regulation is based on the structure of the SAF-T file, which should be submitted by large enterprises, as requested by tax authorities. Daily SAF-T bank statements should include the following information:

  1. details of the sender and recipient of the payment (name, address, tax identification number NIP or statistical number REGON, if available);
  2. account number of the sender and the recipient;
  3. date and time of debiting the sender’s account or date and time of a cash payment;
  4. amount and currency;
  5. title and description of a payment order;
  6. account balance of the company after the payment - for data provided by the bank or credit union keeping the company’s account;
  7. details of a virtual account created to identify mass payments, if a payment order credits such an account - for data provided by a bank or credit union keeping the credited account of the company.

Planned effective date of the amendment is 1 September 2017. 

Rapid reaction mechanism?

As indicated in the explanatory statement of the bill, the amendment objective is to prevent tax fraud and offence, including carousel fraud, through rapid identification of suspicious transactions and checking the revenue and expenses declared against the account throughput. Daily bank statements will enable rapid reaction of tax authorities to undesirable behaviour of taxpayers, which should protect honest taxpayers against fraudulent actions of their counterparties.

Authors:

Ernest Frankowski | Partner in Tax Advisory Department

Tomasz Stankiewicz | Senior Manager in Tax Advisory Department

Igor Roman | Senior Manager in Tax Advisory Department

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