Purchase invoices in VAT and JPK records - everything you need to know!

Service-Tax

One of the basic obligations of VAT payers is to keep records of tax activities performed, on the basis of which the tax is settled. The basic registers in this regard are the sales record and the purchase record. In the article below, we will analyze the position of the purchase invoice in the VAT register and explain the new taxpayers' obligation to send Uniform Audit Files.

Purchase invoices in the VAT register

The purchase invoice received from the seller and booked in the VAT register, which is the basic document confirming the purchase of a given product, affects the determination of the amount of input tax in a given settlement period, while the tax authorities verify the correctness of such a settlement. On the basis of the records, the tax liability for a given accounting period is calculated and shown. Without the relevant data, recorded in a legible manner, the taxpayer in most cases would not be able to settle the tax correctly. All invoices are entered in the register. It is worth noting that the VAT Act does not provide for any template of such a register, therefore the taxpayer may keep the register in any form, subject to the condition of including all the elements required by the regulations.

Therefore, the obligation to keep full records rests primarily on active VAT taxpayers. As it follows from the provisions on registration, an active VAT taxpayer is an entity that does not benefit from the subjective tax exemption and does not only perform tax-exempt activities pursuant to Art. 43 sec. 1 and art. 82 sec. 3 of the VAT Act.

Pursuant to the wording of the Act, the VAT register should contain the data necessary to determine the subject and base of taxation, the amount of tax due, adjustments of output tax, the amount of input tax reducing the amount of output tax, input tax adjustments, amount of tax payable to the tax office or refund thereof. office, as well as other data used to identify individual transactions, including the number by means of which the counterparty is identified for the purposes of tax or value added tax.In the absence of an express prohibition, it is possible to keep several records, separately for individual groups of input tax transactions, using different IT tools.

Particularly large doubts among taxpayers are caused by the provision concerning other data used to identify individual transactions. This means that the tax authorities will expect taxpayers to provide detailed purchase data. As part of this data, it will be necessary, first of all, to enter the counterparty's tax identifier in the records, in particular its tax identification number.

Purchase invoices in the VAT register and the Standard Audit File

Including the purchase invoice in the VAT register is not the only obligation of the entrepreneur, because on July 1, 2016, the provisions on the so-called Standard Audit File. The main assumption for submitting data under SAF-T is to increase the effectiveness of tax audits. SAF-T is an electronic format in which taxpayers, payers and collectors are required to provide data in the case of keeping tax books using computer programs. The submission of sales and purchase records by taxpayers in the form of a JPK file is to enable the tax office to automatically verify whether purchases and input tax recognized in one entity have been shown as sales and tax due in another entity.

It is also worth noting that the obligation to send SAF VAT was introduced in stages, and ultimately all taxpayers are obliged to send SAF VAT from January 1, 2018. However, it should be borne in mind that the obligation to submit data in the format of the Standard VAT Audit File is only imposed on taxpayers, payers. and collectors keeping tax books with the use of computer programs. Taxpayers, payers and collectors who keep tax books without the use of computer programs, this obligation does not apply.

From the point of view of taxpayers obliged to provide data in the form of SAF files, the entry into force of the provisions in question means, first of all, the need to adapt the IT systems used to generate Uniform Control Files. The introduction of this mechanism will, for obvious reasons, increase the effectiveness of tax audits. The data in the Standard Audit File format enables the tax authorities to carry out the so-called cross-checks.

Structure for JPK records

According to the assumption, the Standard Audit File is based on a specific structure. With regard to the JPK VAT file, its structure includes the structure of VAT sales and purchase records. As for the part concerning the information contained in the invoices, it should be noted that apart from the total value of the invoice, broken down into VAT rates and data allowing the identification of the contractor, the following are also reported: description of a single product (service), its unit price and quantity. In the case of correcting invoices, it is necessary to specify in the structure the reason for the correction and the period it relates to.

Another problem that may be faced by taxpayers is the requirement to provide "A consecutive invoice number, assigned within one or more series, which uniquely identifies the invoice". While in the case of sales invoices the meaning of this field is obvious, when it comes to purchase invoices in the VAT register, it should be noted that their numbers assigned by different exhibitors may repeat at the buyer. As a result, providing the number of such an invoice in the structure will not meet this condition. Therefore, it seems that the most appropriate reporting will also be the numbers assigned by the issuer for cost invoices - it will, however, raise a number of IT problems when creating a JPK file.

Corrective invoices can also be problematic. Structures require reporting not only the amounts of the correction, but also the reasons for it. Since such data is rarely stored in the accounting system, the company must either start recognizing it in the system or adopt some simplification. Similar problems are related to the necessity to report the period covered by the correcting invoice (if it concerns more than one invoice).

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