New versions of the VAT structure and Tax Revenue and Expense Ledger for the Standard Audit File
Changes as of 1 January 2017
Tax Alert 23/ 2016
On 28 October 2016 the Ministry of Finance published new versions of VAT structure and Tax Revenue and Expense Ledger for the Standard Audit File. The changes will come into force on 1 January 2017.
As announced earlier the Ministry of Finance embarked on changing the structures of SAF. The first changes were introduced to VAT and Tax Revenue and Expense Ledger. The new structures will come into force on 1 January 2017. Nevertheless the first reports drafted with the use of a new SAF_VAT should appear in February 2017 and cover January 2017.
Changes in the VAT structure
The new structure has either amended contents (new fields which were absent in the earlier structure) or functions (e.g. changes in the names of fields or their order). In both cases the changes affect the shape of the .xml file and will necessitate changes in the manner of preparation of the Standard Audit File.
a) content-related changes
Changes which directly affect the scope of data which should be included in the Standard Audit File fall into five categories:
1. Indicating corrections
The local type CelZlozeniaJPK (SAF_Purpose) was changed into an elementary data type CelZlozenia (Purpose) which in reality results in an addition of version 2 to the purpose of filing the SAF file, i.e. a correction.
This way the Ministry of Finance separated filing SAF corrections from the initial file. So far each correction overwrote the initial SAF file because no other version but version 1 could be selected.
With the new solution the initial SAF file should be labelled version 1 and every subsequent correction for a given period should be labelled as version 2.
2. New fields in the sales evidence
In the new .xml files taxpayers will be obliged to complete two additional fields in the VAT sales.
The first is NrKontrahenta (counterparty number). Here the tax identification number of the buyer must be given. The second is K_39 and has been added following changes introduced to VAT returns. The field is intended for evidencing intra-community acquisition of fuels.
The K_39 field changes the numbering of subsequent fields which have been earlier included in the structure.
3. New fields in the purchases evidence
Purchases evidence has also been expanded by two new fields. These are DataZakupu (purchase date) which must contain the date of the proof of purchase and K_50 which is intended for adjustment of input tax referred to in Article 89b.4 of the VAT Act (the adjustment is made by the debtor due to the so-called bad debt relief).
4. Changes in the type of fields from optional to obligatory
The Ministry of Finance changed the name and type of two fields: NazwaNabywcy (buyer name) was changed to NazwaKontrahenta (counterparty name) and AdresNabywcy (buyer address) to AdresKontrahenta (counterparty address). In both cases the type of field was changed from optional to obligatory.
5. Other content-related changes
There are also two additional changes which affect the contents of data reported in the SAF file.
The mechanisms klucz_LpSprzedaz and klucz_LpZakup, which imposed numbering of all items, starting with number 1, and prevented any gaps in the numbering, were removed.
A local type TAdresJPK was introduced so that the address details given in the heading of the SAF file must be Polish. Certain obligatory fields were changed into optional, however, the city/town name and country code remained obligatory.
b) functional changes
The above changes require appropriate presentation in the maps drafted for the purposes of SAF file reports through addition or removal of data. Other changes are functional. This means that the changes themselves do not affect the scope of data necessary to create a SAF file, however, they require changes in the file structure due to changes in the names of fields and their order.
- These include:
- In the node SprzedazWiersz (sale line) − change in the name NrDokumentu (document number) to DowodSprzedazy (proof of sale)
- In the node SprzedazWiersz (sale line) − change in the order of items to:
- NrKontrahenta (counterparty number)
- NazwaNabywcy (buyer name)
- AdresNabywcy (buyer address)
- DowodSprzedazy (proof of sale)
- DataWystawienia (date issued)
- DataSprzedazy (sale date)
- In the node ZakupWiersz (purchase line) − change in the name NrIdWystawcy (issuer ID) to NrDostawcy (supplier no)
- In the node ZakupWiersz (purchase line) − change in the name NazwaWystawcy (issuer name) to NazwaDostawcy (supplier name)
- In the node ZakupWiersz (purchase line) − change in the name AdresWystawcy (issuer address) to AdresDostawcy (supplier address)
- In the node ZakupWiersz (purchase line) − change in the name NrFaktury (invoice number) to DowodZakupu (proof of purchase)
- In the node ZakupWiersz (purchase line) − change in the name DataWplywuFaktury (invoice receipt date) to DataWplywu (receipt date)
- In the node ZakupWiersz (purchase line) − change in the order of items to:
- NrDostawcy (supplier number)
- NazwaDostawcy (supplier name)
- AdresDostawcy (supplier address)
- DowodZakupu (proof of purchase)
- DataZakupu (purchase date)
- DataWplywu (receipt date)
Consequences of the changes
Taxpayers who are now obliged to submit SAF files should expect that their earlier reports will need to be verified. The changes are necessary not only in the names of columns, but also in their order. New fields must be added in the right way as new data will be later extracted from the accounting systems.
It is also important to remember to apply the new structure to the right point in time when submitting SAF files for the end/beginning of periods, i.e. in the case of the VAT structure − with respect to January 2017. Adjustments should be reported using the structure valid for a given period.