E-documents as the basis for entries in the KPiR and VAT registers


Electronic document workflow in the company (e-documents) is becoming more and more popular among entrepreneurs because it guarantees not only convenience and improvement of internal processes, but in many cases it is also a significant saving. When it comes to accounting, companies often stick to traditional, paper documents, mainly for fear of being questioned by the authorities after. Is it possible to include expenses documented with accounting documents in the form of scans as tax deductible costs? Can e-documents be considered as the basis for entries in the KPiR and VAT registers?

Documenting the cost incurred

As a rule, in order for an expense to be booked as a tax deductible cost, it must meet the definition of a cost regulated by the Personal Income Tax Act. Pursuant to Art. 22 of the aforementioned Act, the tax deductible cost may be the cost incurred in order to achieve revenues or to preserve or secure their source, with the exception of those listed in Art. 23. What does this mean in practice?

A tax cost may therefore be a rationally incurred expense related to the conducted business activity, and it is the taxpayer's responsibility to adequately justify that it serves the purpose of generating revenues. It is also worth noting that there are categories of expenses which, notwithstanding the fact that they are not listed in Art. 23 of the Act, cannot be a company expense, e.g. representation or other personal expenses (e.g. glasses for entrepreneurs, a suit).

Meeting the definition of a cost alone is not sufficient to enter an expense into the records. In addition, the taxpayer must also properly document it, and there are strictly defined accounting vouchers for this. They are enumerated in the regulation on keeping the tax book of revenues and expenditures issued by the Minister of Finance.

To sum up, the cost of obtaining revenue will be an expense that meets all of the following conditions:

  • it was incurred by the taxpayer in connection with his business activity,

  • the purpose of incurring it was to obtain revenues, preserve or secure their source,

  • is definitive (real),

  • has been properly documented,

  • has not been mentioned in Art. 23 of the PIT Act and is not excluded from its provisions.


The definite nature of the expenditure means that it has not been returned to the entrepreneur. Moreover, due to this condition, tax deductible costs do not constitute an advance payment for future transactions, as they are not, as a rule, final.

Which documents can be the basis for accounting?

The basis for recognizing expenses in company costs are:

  • VAT invoices, margin VAT invoices, RR VAT invoices, invoices - cash method;

  • customs documents;

  • bills;

  • correction invoices and correction notes.

The following evidence allows us to conclude that an economic operation was carried out in accordance with its actual course:

  • accounting notes;

  • evidence of shifts;

  • proofs of postage and bank charges;

  • other proofs of fees;

  • daily statements of evidence;

  • internal evidence;

  • receipts or vouchers;

  • descriptions or specifications of materials or commercial goods received.

The listed evidence should, in particular:

  • reliably identify the issuer or indicate the names and addresses of the parties involved in the business operation they relate to,

  • define the subject of an economic operation, its value, and (if possible) its quantification,

  • contain signatures of persons authorized to properly document business operations.

Form of accounting vouchers - paper version or e-documents?

The provisions of the act on personal income tax or the regulation of the Minister of Finance on keeping a tax book of revenues and expenditures do not contain requirements as to the form in which the taxpayer should document the cost. Therefore, it can be assumed that the form of accounting vouchers does not have to be a paper version in advance. E-documents (e.g. in the form of a scan) can also be used for posting.

E-documents as the basis for entries in the KPiR and VAT Registers

The issue of whether e-documents can be the basis for posting expenses charged to tax deductible costs was raised, among others, by director of the Tax Chamber in Katowice in the individual interpretation of March 12, 2015 (IBPBI / 2 / 423-1433 / 14 / KP). In the explanation, he draws attention to the provisions of the tax ordinance, and more precisely, art. 180 § 1, pursuant to which, as evidence, anything that may contribute to the clarification of the case, and at the same time is not contrary to the law, should be admitted. Evidence in tax proceedings may be evidence that may be supplemented, for example, in the course of tax proceedings, and the transaction may be confirmed by the contractor.

E-documents can therefore be the basis for booking the expense against tax costs, because the regulations do not indicate the form that accounting documents must have - whether it must be a paper document or a scan. The most important thing is that the e-documents can be considered as accounting vouchers (here you should return to the regulation on maintaining the KPiR) and whether they meet the formal requirements, i.e. whether they have mandatory data to be recognized, e.g. as an electronic invoice.

The tax authorities emphasize, however, that the possibility of booking scans of documents is considered correct, while in the event of initiating tax proceedings, it should be possible to supplement and verify them with the contractor.