JPK_VDEK – new structure

The Ministry of Finance submitted the new JPK (ang. SAF-T, Standard Audit File for Tax) for public consultation: JPK_V7M and JPK_V7K, which are the successors of JPK_VAT. Differentiation of structures is caused by the adjustment of JPK for taxpayers who settle on a monthly basis – V7M or on a quarterly basis – V7K. New files contain additional structures and fields related to declarations, e.g., VAT-7, VAT-ZZZ, VAT-ZD, VAT-ZD, VAT-ZT. Ultimately, JPK_V7M and JPK_V7K are to replace the submission of these declarations in paper form, which we already wrote about on our blog in April.

An additional element is the Declaration, in which the taxpayer will be obliged to complete the fields concerning, among others:

✓ The amount of tax payable to the tax office;
✓ Amounts to be refunded to the account indicated by the taxpayer;
✓ Whether and by what date a tax refund is requested to the VAT account;
✓ Refund credits for future receivables;
✓ Amounts of a refund to be credited against future entitlements;
✓ Type of future receivable;
✓ Amounts to be carried over to the following accounting period;
✓ Whether and which activities specified in the Act were performed in a given settlement period;
✓ Whether a reduction in tax liability is used;
✓ Total amounts of tax base adjustments;
✓ Total adjustment of output tax.

The structures made available contain information that may seem confusing. An example are the selected values of an optional field associated with the code of a group of traded goods or services. More specifically, some of them indicate the way in which the transaction was conducted rather than the code of a group of goods or services, e.g., the value of the code „Transactions subject to the split payment mechanism” or „Intra-Community supply of goods following the importation of those goods under procedure 42 (import)”.

We do not yet know the outcome of the consultations, which ended on 16 August this year. The Ministry of Finance did not issue any comments on the published structures. Nevertheless, the information provided by the Ministry gives an idea of the challenge faced by large entrepreneurs from April 1, 2020, when JPK_V7M/K will come into force. For other entrepreneurs, the entry into force is scheduled for July 1, 2020.