Will it be possible to send or transmit JPK data in several files?

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From July 1, 2016, entrepreneurs are required to provide information about the records kept for VAT purposes in the form of the Uniform Control File (JPK). Additionally, on each request of the tax office, accounting data should be provided in the form of SAF-T. From January 2017, this obligation also covered small and medium-sized enterprises. From January 2018, also all active VAT payers are obliged to submit VAT records in the form of SAF-T. In this state of affairs, many entrepreneurs' questions related to the above obligations arise, e.g. is it possible to send JPK in several files?

What is JPK?

Standard Audit File-Tax - SAF-T is a set of data created from IT systems of an economic entity through direct data export, containing information on economic operations for a given period, having a standardized layout and format (XML schema) enabling its easy processing. Check below whether it will be possible to send JPK in several files.

Purpose of introducing JPK

The primary purpose of the Standard Audit File is to remove the barrier to the transmission of electronic data. The effect of this will be the reduction of the inspection time, reduction of its nuisance and reduction of costs. In many cases, the transfer of the file will take place only as part of checking activities, after which the inspection at the taxpayer's office will not be necessary at all. Taxpayers will also gain a new internal control mechanism that will allow them to monitor the work of accounting services. An additional effect of the introduced solution may be the use of the structure of the statement of invoices as a communication tool between taxpayers. It will be possible to transfer invoice statements in XML format, the accounting of which can be automated. The benefit for the administration will be the automation of tax data verification. It will gain a tool enabling quick checking and control activities. Access to structured data will allow for quick identification of irregularities and accelerate confirmation of the correctness of settlements. Quick identification of irregularities will allow for more effective counteracting such phenomena as VAT fraud or tax avoidance.

An additional benefit will be the possibility of standardizing checking and control procedures, which should translate into more effective management of teams performing control activities. It will also be important to reduce the costs associated with the increasing use of electronic documentation.

The Ministry of Finance has developed and published on its website answers to the most frequently asked questions about SAF-T by taxpayers. Due to a very large number of problems, they were divided into three parts. The above makes finding the answer a bit more difficult.

Sending VAT records in the form of SAF-T

Based on the information provided by the Ministry of Finance, information on VAT records in the form of SAF-T must be prepared and sent in one file. Transmission of the JPK structure in the new version, ie JPK_VAT in one file, is related to the automation of the verification of the transferred data. The above, as we have already emphasized, results from the answer of the Ministry of Finance included in the information brochure on the JPK_VAT structure. Thus, it is not possible to send JPK in several files. At this point, the question should be asked whether it can be done in certain circumstances.

Sending records in the form of JPK in several files

Technical problems or other circumstances do not give the right to send VAT records in the form of JPK in several files. This would make control very difficult. Thus, no technical problems justify sending JPK_VAT records in several files.

Sending JPK in several files

The information on the website of the Ministry of Finance shows that we can provide SAF-T in several files. In response to question no. 5 "Answers to questions about JPK part 2",

Regarding the submission of JPK in several files, the following questions were asked:

Will it be possible to prepare a separate file for each structure due to e.g. the fact of extracting data from different systems? That is, if the enterprise runs the so-called full accounting, will present JPK in the form of 5 files (accounting books, bank statement, VAT purchase and sale records, warehouse, VAT invoices)?

• If the above is true, will it be possible to separate each of the above files into monthly periods adding up to the period for which the JPK will be requested? (…)

Considering the above answer, it should be stated that a separate file can be prepared for each structure. The reason for this may be, for example, the use of different systems.

To sum up, sending several JPK files can currently only concern the transfer of data in this form at the request of the tax authority (it is not possible to submit several files for VAT records).

It should be emphasized that the Ministry of Finance is constantly refining SAF-T structures, thus the above may change.