Introduced on 1 October 2020, the new VAT SAF-T file replaced the previous VAT-7 return and VAT records submitted by taxpayers in the SAF-T format. Consequently, the scope of data under the reporting obligation got significantly extended. Moreover, the new regulations provide for penalties for any reporting irregularities. Below we present the key information on the new SAF-T and examples of services provided by KPMG to support implementation of the new reporting structure.

General information
The new SAF-T file covers:

  • data related to tax settlements currently covered by the VAT-7 return;

  • information provided via separate documents submitted jointly with the VAT return, e.g. VAT-ZZ (application for a refund), VAT-ZD (bad debt relief) or VAT-ZT (application for faster tax refund);

  • information covered by the SAF-T_VAT records;

  • indication of the type of goods / service (13 groups of goods and services specified under GTU codes, e.g. specific categories of waste; electronic devices; medicines; consulting, accounting, marketing and management services, etc.);

  • indication of the procedure (13 special procedures, e.g. transactions subject to the obligatory split payment mechanism, transactions with related entities, delivery of vouchers, import of goods);

  • information on type of document (e.g. an internal document or a report from a fiscal cash register).

Importantly, in the event of any error in the SAF structure preventing the authority from verifying the correctness of the transaction, a fine of PLN 500 may be imposed for each error, unless the taxpayer corrects the submitted SAF within 14 days.

How we can help

KPMG is ready to support you in analysing the correct implementation of JPM_V7M and JPK_V7K and in adjusting the applicable procedures to the new SAF-T requirements.

We offer comprehensive assistance, covering both substantive (ensuring compliance of the new SAF-T with the existing tax law requirements) and IT support.

Services provided by KPMG are grouped in three areas presented below. The scope and type of services may be tailored to your current needs.

Conducting workshops to correctly establish the new scope of information covered by the SAF-T reporting obligation

KPMG may organize workshops dedicated to identifying the new scope of information covered by the reporting obligation.

As part of the service, KPMG experts will assess the transactions carried out by the Company to identify items subject to the new reporting duties (considering the relevant GTU codes, indication of the type of transactions and types of documents). The analysis takes place based on sample documents and information provided by the Company.

The workshops can be delivered in person or online. Following the analysis, KPMG will elaborate guidelines (a summary report) identifying data that should be prepared and included by the Company in the new SAF-T file.

Comprehensive advisory and technical support for implementation of the new reporting scheme

KPMG may provide you with comprehensive technical and advisory support. Depending on your needs, it may include:

  • identification of the types of data covered by the reporting obligation and analysis thereof in source systems,

  • identification of information gaps and methods of acquiring the missing data (including indication of the scope of changes to be introduced into the source systems),

  • mapping to the SAF-T schema,

  • determination of the scope of updates that must be made to source systems (e.g. SAP, Oracle) and support in update introduction,

  • providing a license for and subsequent implementation of KPMG’s proprietary IT solution (JPK TOOL) allowing to import, validate and submit the data in the new SAF-T format,

  • providing for continuous use of KPMG’s proprietary solution to handle SAF-T reporting.

Service consisting in generating VAT SAF-T files and validating the generated files

If you are not interested in permanent implementation of an external IT solution or making changes to the accounting systems in place, KPMG may offer you a one-off service consisting in generating the SAF-T file via KPMG’s proprietary IT solution (JPK TOOL).

Moreover, depending on your current needs, KPMG may verify (validate) the first SAF-T file generated for your organization or provide a recurring service consisting in validation of the generated files.

SAF-T on demand

It becomes a common practice for tax authorities to demand from taxpayers, on various stages of audits or tax proceedings, to provide ‘SAF-T files on demand’, covering SAF-T structures other than those encompassed by VAT SAF-T in monthly reporting, i.e.:

  • books of accounts – JPK_KR,

  • bank statement – JPK_WB,

  • warehouse – JPK_MAG,

  • VAT invoices – JPK_FA,

  • VAT invoices for lump-sum farmers - JPK_FA_RR,

  • revenue and expense ledger– JPK_PKPIR,

  • revenue registry – JPK_EWP.

Also in this regard KPMG may provide you with extensive support, from substantive analysis, through data mapping, to the implementation of an IT solution for generating the required reports.

See also