Central register of invoices - what is it and what is its task?


The Central Register of Invoices (hereinafter referred to as CRF) causes fear among many entrepreneurs that the state wants to have a very large amount of control over their business activities. When reading the daily press, taxpayers may be concerned that the Ministry of Finance is planning a solution consisting in collecting all issued invoices in the so-called cloud. The Ministry believes that such a solution would be very difficult to implement and would interfere with business activities too much. Moreover, this solution would be very costly. There are almost two million VAT payers in Poland who use very different systems. Thus, this solution was abandoned.

Central register of invoices and related solutions

The Ministry of Finance plans that the new invoice register will be a base built on the basis of the new JPK_VDEK file structure. It is assumed that the basic version of the registry will be available from 01 July 2019. The JPK_VDEK file will replace the JPK_VAT file and VAT-7 and VAT-7K declarations. The taxpayer who sends his JPK_VDEK files will also send information about all invoices he has issued or received. The above information will go to the central database of the Ministry of Finance, where the so-called Central Invoice Register. So it will be information about all invoices.

Planned launch of a feedback channel for taxpayers

The Ministry of Finance also planned earlier to launch a feedback channel for taxpayers. In addition, initially they wanted to shorten the periods for which JPK_VAT files will be sent. Thanks to the feedback system, the taxpayer would receive feedback from the Tax Authority that the JPK_VAT file submitted by him includes purchase invoices that have not been reported by the sellers. Thus, this register is ultimately not only to be used for tax audit. Feedback would allow taxpayers to check their contractor (whether the invoices issued by him are included in the register).

JPK control

Currently, information about discrepancies in the contractors' JPK files is sent only to the tax authorities. In the event of discrepancies, the taxpayer must take into account the tax audit. When sending JPK, he does not know whether his contractor has also reported invoices issued for him. Thus, the tax services must inform taxpayers about discrepancies and, in extreme cases, initiate an inspection. By making a mistake, a taxpayer may be exposed to negative sanctions and interest.

No negative effects in the event of self-correction of errors

The Ministry of Finance predicts that if you correct errors yourself, you will be able to avoid negative consequences, such as sanctions or default interest. Failure to correct the JPK file within 14 days from the date of the request of the head of the tax office will result in the imposition of a fine on the entrepreneur in the amount of PLN 500. The above solution will be beneficial for both taxpayers and tax authorities. Tax authorities will have less work to do as taxpayers themselves will be able to correct their mistakes. The incentive of non-sanctions and no interest will surely make them check their accounts.

JPK - shortening the periods for which the report will be sent

The Ministry of Finance previously planned to significantly reduce the time for SAF-T reporting. On the one hand, the above information is beneficial because we will be able to check our contractors. On the other hand, excessive shortening of this period may be very burdensome, especially for small taxpayers. In most cases, they outsource their accounting to accounting offices. Too frequent reporting can make it difficult to run your business. The taxpayer will have to constantly think about shipping and delivering documents to the accounting office, instead of dealing with the current affairs of the company. For now, the project provides for the submission of information to the CRF on the basis of SAF shipments on a monthly basis.

Estimated date for introducing changes

The Ministry of Finance plans that the above system will start in July 2019. In addition, it is planned to eliminate the submission of VAT returns. The Ministry of Finance plans to adjust the data sent in the form of SAF-T to supplement them with those that are included in the declaration today, i.e. creating a new JPK_VDEK file structure.

The Central Register of Invoices should be assessed positively. Thanks to it, taxpayers will be able to check their contractors on an ongoing basis.

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